EXHIBIT A¶
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK¶
CASE NO. 15-CV-07433-RWS¶
Plaintiff,¶
-against-¶
GHISLAINE MAXWELL,¶
Defendant.¶
250 N. Australian Avenue, Suite 1400 West Palm Beach, Florida 33401 Friday, September 9, 2016 8:35 a.m. - 2:08 p.m.¶
CONFIDENTIAL¶
VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN¶
Taken before Darline M. West, Registered Professional Reporter, Notary Public in and for the State of Florida At Large, pursuant to Notice of Taking Deposition filed by the Plaintiff in the above cause.¶
MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026
¶
¶(866) 624-6221
1 APPEARANCES:
2 On behalf of the Plaintiff:
3 THE UNIVERSITY OF UTAH,
4 S.J. QUINNEY COLLEGE OF LAW
5 383 South University Street
6 Salt Lake City, Utah 84112
7 Phone: 801.585.5202
8 E-mail: Cassellp@law.utah.edu
9 By: PAUL G. CASSELL, ESQ.
10 -and-
11 BOIES SCHILLER & FLEXNER, LLP
12 401 East Las Olas Boulevard
13 Fort Lauderdale, Florida 33301
14 Phone: 954.356.0011
15 E-mail: Smccawley@bsfllp.com
16 By: SIGRID S. MCCAWLEY, ESQ.¶
17 On behalf of the Defendant:
18 HADDON [REDACTED]
19 150 East 10th Avenue
20 Denver, Colorado 80203
21 Phone: 303.831.7364
22 E-mail: Jpagliuca@hmflaw.com
23 By: JEFFREY PAGLIUCA, ESQ.¶
24 On behalf of the Witness, Jeffrey Epstein:
25 ATTERBURY GOLDBERGER & WEISS, P.A.
26 One Clearlake Centre, Suite 1400
27 250 Australian Avenue South
28 West Palm Beach, Florida 33401
29 Phone: 561.659.8300
30 E-mail: Jgoldberger@agwpa.com
31 By: JACK A. GOLDBERGER, ESQ.
32 -and-¶
24 (Appearances continued on the next page)¶
1 IN D E X
2 WITNESS: PAGE:
3 JEFFREY EDWARD EPSTEIN
4 DIRECT EXAMINATION
5 BY MR. CASSELL:
6 CROSS-EXAMINATION
7 BY MR. PAGLIUCA:
8 REDIRECT EXAMINATION
9 BY MR. CASSELL:
10 CERTIFICATE OF OATH
11 REPORTER'S CERTIFICATE
12 - - -
13 E X H I B I T S¶
14 - - -
15 Description Page
16 Plaintiff's Exhibit JE1 Transcript of the
17 deposition of
18 Ms. Maxwell taken on
19 April 22nd, 2016
20 Plaintiff's Exhibit JE2 Document with titles
21 of books
22 Plaintiff's Exhibit JE3 Photograph depicting
23 Prince Andrew,
24 Maxwell, and Virginia
25 Plaintiff's Exhibit JE4 E-mail that Jeffrey
26 Epstein sent to
27 Maxwell on
28 January 12th, 2015¶
1 APPEARANCES:
2 [REDACTED] G. WEINBERG, P.C.
3 20 Park Plaza, No. 1000
4 Boston, Massachusetts 02116
5 Phone: 617.227.3700
6 E-mail: Marty@martinweinberglaw.com
7 By: [REDACTED] G. WEINBERG, P.C.
8 (Appearing telephonically)¶
9 ALSO PRESENT:
10 RYAN KICK - Video Technician
11 DARLINE [REDACTED] WEST - Court Stenographer¶
12 Plaintiff's Composite E-mail Jeffrey
13 Exhibit JE5 Epstein received from
14 Ms. Maxwell on about
15 July 18th, 2009
16 Plaintiff's Exhibit JE6 E-mail string between
17 Jeffrey Epstein and
18 Ms. Maxwell on about
19 March 25th, 2011
20 Plaintiff's Exhibit JE7 Transcription of a
21 string of e-mails
22 between Jeffrey
23 Epstein and Ms.
24 Maxwell in about May
25 of 2011
26 Plaintiff's Exhibit JE8 E-mail that Jeffrey
27 Epstein sent to
28 Maxwell on
29 January 15th, 2015
30 Plaintiff's Exhibit JE9 Document 361-46 on
31 the public record in
32 the case Jane Doe
33 versus United States
34 908CD80736 in the
35 Southern District of
36 Florida, a document
37 signed by Gerald
38 Lefcourt and
39 Alan Dershowitz
40 Plaintiff's Exhibit Subpoena in this case
41 JE10 for Jeffrey Epstein
42 to appear at
43 deposition
44 Plaintiff's Exhibit Transcript of Ms.
45 JE11 Maxwell, taken on
46 July 22, 2016¶
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1 QUESTIONS MARKED BY THE REQUEST OF COUNSEL:¶
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3 PAGE/LINES¶
4 Page 69, lines 24 through 25¶
5 Page 70, lines 2 through 16¶
6 (At the request of Mr. Pagliuca)¶
7 Page 280, lines 4 through 6¶
8 (At the request of Mr. Cassell)¶
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Page 7¶
1 J. Epstein - Confidential¶
2 PROCEEDINGS¶
3 - - -¶
4 VIDEO TECHNICIAN: We are now on the¶
5 record. This begins videotape No. 1 in the¶
6 deposition of Jeffrey Epstein in the matter¶
7 of [REDACTED] versus Maxwell.¶
8 Today is September 9th, 2016. The time¶
9 is 8:35 a.m. This deposition is being taken¶
10 at 250 North Australian Avenue, West Palm¶
11 Beach, Florida. The videographer is¶
12 Ryan Kick. The court reporter is¶
13 Darline West. We both represent Magna Legal¶
14 Services.¶
15 Will counsel and all parties present¶
16 state their appearance and whom they¶
17 represent.¶
18 MR. CASSELL: I can begin. My name's¶
19 Paul Cassell, and I represent Miss [REDACTED]¶
20 [REDACTED]¶
21 [REDACTED]. MCCAWLEY: Sigrid McCawley with¶
22 Boies, Schiller & Flexner on behalf of¶
23 [REDACTED]¶
24 MR. PAGLIUCA: Jeff Pagliuca appearing¶
25 on behalf Gwen Maxwell.¶
Page 8¶
1 J. Epstein - Confidential¶
2 MR. GOLDBERGER: And Jack Goldberger on¶
3 behalf of the witness, Jeffrey Epstein.¶
4 And on the phone is?¶
5 MR. WEINBERG: [REDACTED] Weinberg by¶
6 telephone on behalf of the witness,¶
7 Jeffrey Epstein.¶
8 VIDEO TECHNICIAN: Will the court¶
9 reporter please swear the witness.¶
10 THE COURT REPORTER: Okay. Sir, could¶
11 you raise your right hand.¶
12 Do you swear to tell the truth, the¶
13 whole truth, and nothing but the truth?¶
14 THE WITNESS: Yes, [REDACTED].¶
15 THEREUPON,¶
16 JEFFREY EDWARD EPSTEIN,¶
17 called as a witness on behalf of the Plaintiff¶
18 herein, having been first duly sworn, was examined¶
19 and testified as follows:¶
20 DIRECT EXAMINATION¶
21 BY MR. CASSELL:¶
22 Q. All right. Sir, you understand that my¶
23 client is [REDACTED]?¶
24 MR. GOLDBERGER: I'm sorry,¶
25 Mr. Cassell. Before we start, let -- let me¶
Page 9¶
1 J. Epstein - Confidential¶
2 just discuss something on the record.¶
3 I understand there's a protective order¶
4 in place on this case concerning¶
5 confidentiality in this depositions. And as¶
6 I understand the protective order, either¶
7 party can designate the -- the proceeding as¶
8 confidential, and I understand counsel for¶
9 Miss Maxwell is going to do that in this¶
10 case.¶
11 MR. PAGLIUCA: That's correct. I'm¶
12 designating this deposition as confidential.¶
13 Any other stips?¶
14 MR. GOLDBERGER: Huh?¶
15 MR. PAGLIUCA: Any other stips?¶
16 MR. GOLDBERGER: No. We're good for¶
17 now.¶
18 MR. PAGLIUCA: Okay.¶
19 BY MR. CASSELL:¶
20 Q. All right. Sir, you understand I'm an¶
21 attorney representing Miss [REDACTED]?¶
22 [REDACTED]¶
23 A. I've been advised by my counsel to assert¶
24 my rights under the Fifth Amendment of the United¶
25 States Constitution as to any and all questions that¶
1 J. Epstein - Confidential 2 could result in a waiver of my Constitutional 3 privileges. I understand that one of the basic 4 functions of the Fifth Amendment, according to the 5 United States Supreme Court, is to protect all 6 citizens, including even innocent persons who 7 otherwise might be insnared by ambiguous 8 circumstances. On the advice of counsel, I assert my 9 rights under the Fifth Amendment and respectfully 10 decline to answer your question.¶
11 MR. CASSELL: Mr. Goldberger, it's your 12 position that having him acknowledge who my 13 client is creates a realistic risk of 14 incrimination?¶
15 MR. GOLDBERGER: We're not going to 16 debate at this deposition whether the 17 implication of the Fifth Amendment privilege 18 is proper or not proper. We are simply¶
19 asserting the privilege. And if that needs 20 to be discussed or litigated somewhere else, 21 well be happy to do so, so...¶
22 BY MR. CASSELL:¶
23 Q. If I refer to Virginia today, I want you to 24 understand that I'll be referring to my client,¶
25 Miss¶
1 J. Epstein - Confidential 2 answer would be edited and -- and would be 3 the full answer that Mr. Epstein gave to the 4 first question. Really, your choice on that 5 as to how you would like to proceed.¶
6 MR. CASSELL: Yeah. Whatever you think 7 would be the fastest. I want to get through 8 this.¶
9 MR. GOLDBERGER: Okay.¶
10 MR. CASSELL: And so, obviously, we'll 11 be objecting to many of these invocations 12 already.¶
13 MR. GOLDBERGER: Sure.¶
14 MR. CASSELL: I think that these are 15 improper invocations, but if we're going to 16 litigate that elsewhere, that certainly is 17 one way to proceed.¶
18 MR. GOLDBERGER: Okay. So is it fair 19 to say we've reached an agreement that if 20 Mr. Epstein simply says, the Fifth, the¶
21 answer that would be part of the record for 22 any time these proceedings are used anywhere 23 would be the full invocation Mr. Epstein 24 used in answer to the first question?¶
25 MR. CASSELL: Yes. And I would at the¶
1 2 3 J. Epstein - Confidential Is that an acceptable way to proceed today. sir?¶
4 5 6 A. As I stated before in response to my -- to your earlier question, I am asserting my constitutional right not to respond to that question.¶
7 8 9 10 MR. GOLDBERGER: This would be a good opportunity, I think, to kind of discuss ground rules for the implication of the Fifth Amendment --¶
11 MR. CASSELL: All right.¶
12 13 14 15 16 17 MR. GOLDBERGER: -- as we proceed in this deposition. We've advised you off the record and it's not any surprise to anyone that Mr. Epstein fully intends to invoke Fifth Amendment privileges to all of your questions.¶
18 19 20 We can -- as we answer your questions, and we'll be happy to answer all your questions, we can use the full invocation¶
21 22 23 24 that we did in response to your first question, we can use the invocation that we just did in response to your second question, or we simply can say, Fifth¶
25 Amendment, with the understanding that the 1 J. Epstein - Confidential 2 -- I would then raise an objection to the 3 nonresponsive portion of the invocation. 4 such as, for example, a reference to 5 "innocent persons." It seems to me that's 6 not necessary for him to take the Fifth.¶
7 MR. GOLDBERGER: Okay.¶
8 MR. CASSELL: As long as we have your 9 position and our position both stated all 10 the time, that -- that seems like the most 11 expeditious way to proceed.¶
12 MR. WEINBERG: One other matter, a 13 preliminary matter, which is that we would 14 reserve our right to particularize a full 15 basis based on the record of this case, the 16 record of the CVARC CVRA case, 17 representations that have been made by you 18 and Mr. regarding Mr. Epstein and 19 his potential criminal liability and your 20 intention to seek to rescind his 21 non-prosecution agreement, the admissions 22 taken on the absence of the meaningful 23 Statute of Limitations, in terms of our 24 spelling out, if the Fifth Amendment is 25 challenged in regards to any response by¶
1 J. Epstein - Confidential
2 Mr. Epstein, for instance, a response to
3 whether he even recognizes the name of your
4 client, in the event you choose to challenge
5 the essential applicability of the
6 long-standing Fifth Amendment privilege.¶
7 MR. CASSELL: I'm going to object to
8 Mr. Weinberg defending the deposition in
9 addition to Mr. Goldberg. My
10 understanding of the rules --¶
11 MR. GOLDBERGER: Goldberger. It's
12 Goldberger.¶
13 MR. CASSELL: I'm sorry. I apologize.
14 Mr. Goldberger.¶
15 It seems to me, the standard is one
16 lawyer for one witness. And Mr. Goldberger
17 is a very capable lawyer, so it seems to me
18 Mr. Weinberg should not be allowed to
19 participate by making objections.¶
20 MR. PAGLIUCA: And for the record, I
21 have no objection to Mr. Epstein simply
22 saying, Fifth Amendment in response to any
23 questions and understand that that answer
24 would incorporate all of the first answer
25 that Mr. Epstein gave in this deposition.¶
1 J. Epstein - Confidential
2 MR. GOLDBERGER: Thank you.
3 BY MR. CASSELL:¶
4 Q. Sir, you've been deposed many times before,
5 true?¶
6 A. Fifth.¶
7 Q. You understand the rules regarding the
8 deposition today, true?¶
9 A. Fifth.¶
10 Q. You have legal counsel here today to
11 provide advice to you, should it be necessary at any
12 point, true?¶
13 A. True.¶
14 Q. Is there anything, including any physical
15 conditions or ailments, that would prevent you from
16 giving truthful testimony today?¶
17 A. Fifth.¶
18 Q. Please state your full name.¶
19 A. Jeffrey Edward Epstein.¶
20 Q. Without disclosing where you may have lived
21 in the past, where do you currently reside?¶
22 A. Fifth.¶
23 Q. What state are you a citizen of?¶
24 A. Can you clarify the question?¶
25 Q. Yeah. What state do you consider yourself¶
1 J. Epstein - Confidential
2 to be a citizen of?¶
3 A. Fifth.¶
4 Q. You understand that the case caption on the
5 subpoena you received is [REDACTED] versus
6 Ghislaine Maxwell?¶
7 A. Fifth.¶
8 Q. You know the Defendant in this case,
9 Ghislaine Maxwell, true?¶
10 A. Fifth.¶
11 Q. You first met Maxwell in the early 1990s;
12 isn't that true?¶
13 MR. PAGLIUCA: Object to form and
14 foundation.¶
15 THE WITNESS: Fifth.¶
16 MR. CASSELL: Let me make sure I
17 understand.¶
18 What's the objection to form?¶
19 MR. PAGLIUCA: The question is vague.¶
20 BY MR. CASSELL:¶
21 Q. When did you first meet Ms. Maxwell?¶
22 A. Fifth.¶
23 Q. Where did you first meet Ms. Maxwell?¶
24 A. Fifth.¶
25 Q. What were the circumstances surrounding¶
1 J. Epstein - Confidential
2 your first meeting of Maxwell?¶
3 MR. PAGLIUCA: Object to form and
4 foundation.¶
5 THE WITNESS: Could you repeat the
6 question?¶
7 BY MR. CASSELL:¶
8 Q. What were the circumstances surrounding
9 your first meeting of Maxwell?¶
10 MR. PAGLIUCA: Same objection.¶
11 THE WITNESS: Fifth.¶
12 MR. CASSELL: And when you say "form," you
13 believe that the question that I just asked is
14 vague?¶
15 MR. PAGLIUCA: It is vague. I don't
16 understand what "circumstances" means. It
17 lacks foundation, in that there hasn't been
18 an establishment of any time or place of
19 meeting of Ms. Maxwell or even that he knows
20 Ms. Maxwell under the circumstances of this
21 deposition.¶
22 MR. CASSELL: Right. But you
23 understand there is evidence in the record
24 from which I would have a good faith basis
25 for believing that he has, in fact, met¶
Page 18¶
1 J. Epstein - Confidential¶
2 Ms. Maxwell?¶
3 MR. PAGLIUCA: I'm not going to debate¶
4 what you have a good faith for believing or¶
5 not. My -- my objection stands.¶
6 MR. CASSELL: I'm just confused about¶
7 how there could be a lack of foundation for¶
8 whether they have met, when your client¶
9 testified under oath that she had interacted¶
10 with Epstein repeatedly.¶
11 MR. PAGLIUCA: That's my objection.¶
12 MR. CASSELL: All right.¶
13 BY MR. CASSELL:¶
14 Q. Just so we're clear, the -- the question --¶
15 let me just -- I may have asked this before, but I¶
16 want to make sure we haven't messed -- messed --¶
17 missed anything.¶
18 What were the circumstances surrounding¶
19 your first meeting with Maxwell?¶
20 MR. PAGLIUCA: Same objection. Form¶
21 and foundation.¶
22 THE WITNESS: Fifth.¶
23 BY MR. CASSELL:¶
24 Q. And whenever I use the term "Maxwell"¶
25 today, I wanted it to be clear that I'm referring to¶
Page 19¶
1 J. Epstein - Confidential¶
2 the Defendant in this action, Ghislaine Maxwell.¶
3 Would you consider yourself currently to be¶
4 the boyfriend of Ms. Maxwell?¶
5 MR. PAGLIUCA: Object to form and¶
6 foundation.¶
7 THE WITNESS: Fifth.¶
8 BY MR. CASSELL:¶
9 Q. Have you ever been a boyfriend of¶
10 Ms. Maxwell?¶
11 MR. PAGLIUCA: Object to form and¶
12 foundation.¶
13 THE WITNESS: Fifth.¶
14 BY MR. CASSELL:¶
15 Q. It's true that at some point you had an¶
16 intimate relationship with Miss Maxwell?¶
17 MR. PAGLIUCA: Object to form and¶
18 foundation.¶
19 THE WITNESS: Fifth.¶
20 BY MR. CASSELL:¶
21 Q. You were in a long-term relationship with¶
22 Maxwell from the early '90s through -- through at¶
23 least 2005, true?¶
24 MR. PAGLIUCA: Object to form and¶
25 foundation.¶
Page 20¶
1 J. Epstein - Confidential¶
2 THE WITNESS: Fifth.¶
3 BY MR. CASSELL:¶
4 Q. How long did your long-term relationship¶
5 with Maxwell continue?¶
6 MR. PAGLIUCA: Object to form and¶
7 foundation.¶
8 THE WITNESS: Fifth.¶
9 BY MR. CASSELL:¶
10 Q. You are currently in a relationship with¶
11 Maxwell, true?¶
12 MR. PAGLIUCA: Object to form and¶
13 foundation.¶
14 THE WITNESS: Fifth.¶
15 BY MR. CASSELL:¶
16 Q. You currently have a joint defense¶
17 agreement with Maxwell, true?¶
18 MR. PAGLIUCA: Object to form and¶
19 foundation.¶
20 THE WITNESS: Fifth.¶
21 BY MR. CASSELL:¶
22 Q. You currently have a common interest¶
23 agreement with Maxwell, true?¶
24 MR. PAGLIUCA: Object to form and¶
25 foundation.¶
Page 21¶
1 J. Epstein - Confidential¶
2 THE WITNESS: Fifth.¶
3 BY MR. CASSELL:¶
4 Q. You understand that your interests and¶
5 Maxwell's interests are aligned in this case?¶
6 MR. PAGLIUCA: Object to form and¶
7 foundation.¶
8 THE WITNESS: Fifth.¶
9 BY MR. CASSELL:¶
10 Q. What is your understanding of Maxwell's¶
11 interest in this case?¶
12 MR. PAGLIUCA: Object to form and¶
13 foundation.¶
14 THE WITNESS: Fifth.¶
15 BY MR. CASSELL:¶
16 Q. What is your understanding of your interest¶
17 in this case?¶
18 MR. PAGLIUCA: Object to form and¶
19 foundation.¶
20 THE WITNESS: Fifth.¶
21 BY MR. CASSELL:¶
22 Q. Since the start of 2015, you have¶
23 communicated with Maxwell about how she can best¶
24 respond to allegations made by Virginia?¶
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential 1 J. Epstein - Confidential 2 foundation. 2 What was the nature of your objection 3 THE WITNESS: Fifth. 3 regarding common interest and joint defense 4 BY MR. CASSELL: 4 agreement, Mr. Weinberg? 5 Q. Without going into the substance of any 5 MR. WEINBERG: It was direct status 6 communications you have had, you've communicated with 6 asserting the attorney-client privilege as 7 Maxwell since December 30th, 2014. true? 7 well as the Fifth Amendment. I'm making no 8 MR. PAGLIUCA: Object to form and 8 representations regarding the existence of 9 foundation. 9 any agreement. 10 THE WITNESS: Fifth. 10 MR. CASSELL: All right. You also 11 MR. CASSELL: Can I understand what the 11 objected to my last question based on 12 objection is to form on that particular 12 foundation. What was the foundation 13 question? 13 objection? 14 MR. PAGLIUCA: Do you want to have the 14 MR. PAGLIUCA: There's multiple 15 reporter read it back? 15 foundational issues. We don't know the 16 MR. CASSELL: I can just give it to 16 source of any information that would be 17 you. 17 responsive to the question. It could 18 MR. PAGLIUCA: Sure. 18 contain hearsay and speculation. You know. 19 MR. CASSELL: "Without going into any 19 all of these questions, frankly, lack 20 substance of any communications that you 20 foundation under the circumstances here 21 have had, you have communicated with Maxwell 21. Frankly, I don't believe that there -- it 22 since December 30th, 2014, true?" 22 will be a good faith basis for most of the 23 MR. PAGLIUCA: It's a leading question. 23 questions. I don't believe that most of 24 That's a form objection. 24 these questions will be supported by an) 25 MR. CASSELL: All right. So can we 25 independent evidence.¶
1 J. Epstein - Confidential 1 J. Epstein - Confidential 2 just -- 2 This is simply an exercise for you, 3 MR. WEINBERG: And I would add a 3 Mr. Cassell, to use leading questions to try 4 further objection, which is to the extent 4 to obtain some adverse inference and 5 that any conversations which were pursuant 5 advantage in this litigation, when you know 6 to a common interest agreement, you would 6 that this witness is going to blanketly 7 assert the attorney-client privilege as well 7 assert a Fifth Amendment privilege. 8 as the Fifth Amendment. 8 Frankly, I see no point in actually 9 MR. GOLDBERGER: Right. So that 9 having this deposition since all of these 10 objection we're making as to attorney-client 10 issues are going to need to be litigated 11 privilege in no way waives the Fifth 11 before the court before we can actually have 12 Amendment privilege that has been raised to 12 a determination of what Mr. Epstein may or 13 the question. 13 may not testify about, so... 14 MR. CASSELL: Mr. Weinberg, since 14 MR. CASSELL: My specific question, 15 you're participating over my objection, can 15 though, is -- the question I asked Epstein 16 you confirm that there is a joint defense 16 was, "Without going into the substance of 17 agreement between your client and 17 any communications that you have had, you 18 Ms. Maxwell? 18 have communicated with Maxwell since 19 MR. PAGLIUCA: I'm going to object to 19 December 30th, 20I4?" 20 any interrogation of Mr. Weinberg. He's not 20 Since your client has testified under 21 been noticed for a deposition, he's not 21 oath that she did indeed have communications 22 under oath, and he's not present here. 22 with Epstein since December 30th, 2014, I 23 MR. CASSELL: I'm just trying to 23 can't understand why that question would 24 understand the objection so that I can avoid 24 lack a foundation. 25 it in any future questions. 25 MR. PAGLIUCA: Well, I -- I've made my¶
Page 26¶
1 J. Epstein - Confidential
2 record. It -- it is lacking in foundation.
3 MR. CASSELL: All right.
4 BY MR. CASSELL:
5 Q. Without going into the substance of any
6 communications that you have had, you have
7 communicated with Maxwell since September 21st, 2015,
8 true?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. How many communications have you had with
14 Ms. Maxwell since December 30th, 2014?
15 A. Fifth.
16 Q. What methods of communications have you
17 used when talking to Maxwell in the last two years?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. What e-mail accounts have you used in your
23 communications with Maxwell?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
Page 27¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. What e-mail accounts has Maxwell used in
5 her communications with you?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. What is your cell phone number, sir?
11 A. Fifth.
12 Q. How many cell phones do you have?
13 A. Fifth.
14 Q. Please provide all of the cell phone
15 numbers that you currently have access to?
16 A. Fifth.
17 Q. Please provide all the cell phone numbers
18 that you had access to in 2000 and 2001?
19 A. Fifth.
20 Q. Please provide all of the e-mail accounts
21 that you had access to in 2000 and 2001.
22 A. Fifth.
23 Q. Please provide all of the e-mail accounts
24 that, to your knowledge, Ms. Maxwell had access to in
25 2000 and 2001.¶
Page 28¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. You are a registered sex offender, correct?
7 A. Fifth.
8 Q. In previous depositions, you have stated
9 that you are a registered sex offender, true?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. In June 2008, in open court, you pled
15 guilty to two Florida State felonies, correct?
16 A. Fifth.
17 Q. You were sworn to tell the truth in those
18 public proceedings, true?
19 A. Fifth.
20 Q. In open court, what did you testify that
21 you had done?
22 A. Fifth.
23 Q. And in my previous question, I'm referring
24 to the plea proceeding that was in about June
25 of 2008. Did you understand my question?¶
Page 29¶
1 J. Epstein - Confidential
2 A. Yes.
3 Q. In open court, what things did you say in
4 that hearing?
5 A. Fifth.
6 Q. Did you tell the truth in that hearing?
7 A. Fifth.
8 Q. Did you tell the court that you accepted
9 responsibility for those crimes?
10 A. Fifth.
11 Q. Were you accepting responsibility for those
12 crimes?
13 A. Fifth.
14 Q. Why were you accepting responsibility for
15 those crimes?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. Did you apologize to the victim of your
21 crimes?
22 A. Fifth.
23 Q. One of the crimes to which you pled guilty
24 in open court was soliciting a minor for
25 prostitution, true?¶
Page 30¶
1 J. Epstein - Confidential¶
2 MR. PAGLIUCA: Object to form and¶
3 foundation.¶
4 THE WITNESS: Fifth.¶
5 BY MR. CASSELL:¶
6 Q. Please describe how the solicitation to¶
7 which you pled guilty was accomplished.¶
8 MR. PAGLIUCA: Object to form and¶
9 foundation.¶
10 THE WITNESS: Fifth.¶
11 MR. CASSELL: Can you tell me what the form¶
12 objection was to that?¶
13 MR. PAGLIUCA: Please tell me how the¶
14 solicitation was accomplished?¶
15 MR. CASSELL: Yes.¶
16 MR. PAGLIUCA: Okay. Well, you're¶
17 asking for a legal definition from this lay¶
18 witness as to solicitation, how it was¶
19 accomplished. I don't know what that means.¶
20 Your question is vague, it's ambiguous, it¶
21 calls for a legal conclusion. It's also¶
22 lacking in foundation.¶
23 MR. CASSELL: Because?¶
24 MR. PAGLIUCA: Well, as I understand¶
25 it, your position is that he pled guilty to¶
Page 31¶
1 J. Epstein - Confidential¶
2 made-up crimes that didn't have a factual¶
3 basis and this was a conspiracy between¶
4 Mr. Epstein and the U.S. Attorney's Office¶
5 to avoid prosecution for federal criminal¶
6 charges, which is the basis for your¶
7 challenge to -- in the CVRA litigation, as I¶
8 understand your pleadings. So I'm not¶
9 exactly sure how you can actually have a¶
10 good faith basis for asking that question,¶
11 given your position in writing.¶
12 MR. CASSELL: All right. You've¶
13 mischaracterized our position. And I¶
14 imagine we'll have to discuss that later.¶
15 MR. PAGLIUCA: Sure.¶
16 MR. CASSELL: Since there were¶
17 objections to form, let me just try to ask a¶
18 series of questions, then, to avoid the form¶
19 objection.¶
20 BY MR. CASSELL:¶
21 Q. How did you accomplish the crime that you¶
22 pled guilty to?¶
23 MR. PAGLIUCA: Object to form and¶
24 foundation.¶
25 THE WITNESS: Fifth.¶
Page 32¶
1 J. Epstein - Confidential¶
2 BY MR. CASSELL:¶
3 Q. What did you do that led you to plead¶
4 guilty?¶
5 MR. PAGLIUCA: Object to form and¶
6 foundation.¶
7 THE WITNESS: Fifth.¶
8 BY MR. CASSELL:¶
9 Q. What was your understanding of the legal¶
10 crime to which you were pleading guilty?¶
11 MR. PAGLIUCA: Object to form and¶
12 foundation.¶
13 THE WITNESS: Fifth.¶
14 BY MR. CASSELL:¶
15 Q. What was your understanding of what you¶
16 were admitting in open court that day?¶
17 MR. PAGLIUCA: Object to form and¶
18 foundation.¶
19 THE WITNESS: Fifth.¶
20 BY MR. CASSELL:¶
21 Q. Now, with regard to the two crimes that you¶
22 pled guilty, where did those two crimes take place?¶
23 A. Fifth.¶
24 Q. And I suppose there could be a form¶
25 objection to that question being compound. So to¶
Page 33¶
1 J. Epstein - Confidential¶
2 obviate any issue, I'm going to ask you, was one of¶
3 the victims in that case a girl who was 14 years old¶
4 who we could identify by initials S.G.?¶
5 MR. PAGLIUCA: Object to form and¶
6 foundation.¶
7 THE WITNESS: Fifth.¶
8 MR. CASSELL: And Mr. Goldberger, is -- if¶
9 we refer to the victim in -- I believe it was¶
10 Count 1 or at least one of the accounts by S.G.¶
11 Is that an acceptable way to proceed rather¶
12 than putting her name into the record, or could¶
13 I write her name out and provide that to you and¶
14 your client? What would you -- I want to avoid¶
15 putting the names of 14-year-old sex victims¶
16 into the transcript here.¶
17 MR. GOLDBERGER: It's your deposition.¶
18 MR. CASSELL: All right. So what I'm¶
19 going --¶
20 BY MR. CASSELL:¶
21 Q. Sir, you understand when I use the term¶
22 "S.G." who I'm referring to, true?¶
23 MR. PAGLIUCA: Object to form and¶
24 foundation.¶
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 MR. CASSELL: And what I'm going to do is
3 write the name of the victim and provide that to
4 Mr. Goldberger and to Mr. Pagliuca now, so that
5 when I use the term "S.G.," both Mr. Goldberger
6 and Mr. Pagliuca will have that.
7 MR. GOLDBERGER: Thank you.
8 MR. CASSELL: And if you -- and then we
9 should also provide that, of course, now to
10 Mr. Epstein, so that he'll --
11 MR. GOLDBERGER: He's -- he's seen it.
12 MR. CASSELL: Okay.
13 And then I'm going to do the same thing with
14 the second witness. I'm going to refer to her
15 by the initials [REDACTED]
16 And I'm providing -- Let the record will
17 reflect I'm providing the -- the full name
18 of [REDACTED] to Mr. Goldberger, Mr. Pagliuca, and
19 Mr. Epstein has seen it as well.
20 BY MR. CASSELL:
21 Q. Please describe how you accomplished the
22 solicitation of S.G.
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Please describe how you accomplished the
4 solicitation of [REDACTED]
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. Where was the solicitation of S.G.
10 accomplished?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. Where was the solicitation of [REDACTED]
16 accomplished?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. Isn't it true, sir, that the solicitation
22 of [REDACTED] occurred in your Palm Beach mansion?
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Isn't it true, sir, that the solicitation
4 of S.G. occurred in your Florida -- or I should say,
5 Palm Beach mansion?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Who was regularly in your Palm Beach
11 mansion at the time of the solicitation of [REDACTED]?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 MR. CASSELL: Could I understand the
16 form objection to that question?
17 MR. PAGLIUCA: "Who was regularly
18 in..."
19 Again, these are vague questions with
20 no time frame, which is the form problem of
21 your questions.
22 BY MR. CASSELL:
23 Q. Sir, with regard to my questions, I want
24 you to understand that the time frame is the same
25 time frame for the crime to which you pled guilty.¶
1 J. Epstein - Confidential
2 With regard to that time frame, who was
3 regularly in your house?
4 MR. PAGLIUCA: Form and foundation
5 objection.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. Sir, isn't it true that when you solicited
9 [REDACTED] for sex, Maxwell was regularly in your Palm
10 Beach mansion?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. Sir, isn't it true that when you solicited
16 S.G. for sex, Maxwell was regularly in your Palm
17 Beach mansion?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 And here, Mr. Cassell, there is no
21 evidence that Ms. Maxwell was quote,
22 unquote, regularly in the Palm Beach mansion
23 during the time frame that you're talking
24 about. And so there is no good faith basis
25 to ask that question.¶
1 J. Epstein - Confidential
2 MR. CASSELL: I disagree with your
3 understanding of the record, but we'll take
4 that up at a later time.
5 BY MR. CASSELL:
6 Q. How old was S.G. when you solicited her for
7 sex?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. How old was [REDACTED] when you solicited her for
13 sex?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Isn't it true, sir, that S.G. was under the
19 age of 18 when you solicited her for sex?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. Indeed, sir, isn't it true that S.G. was
25 under the age of 16 when you solicited her for sex?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. How old was [REDACTED] when you solicited her for
7 sex?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. Isn't it true, sir, that [REDACTED] was under the
13 age of 18 when you solicited her for sex?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Sir, isn't it true you arranged for [REDACTED] to
19 come to your Palm Beach mansion for sexual purposes?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. Sir, isn't it true that you arranged for
25 S.G. to come to your Palm Beach mansion for sexual¶
1 J. Epstein - Confidential
2 purposes?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. Sir, isn't it true that you had sex with
8 S.G. at your Palm Beach mansion?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. Sir, isn't it true that you had sex with
14 [REDACTED] at your Palm Beach mansion?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. Sir, it required logistical arrangements
20 for A.H. to come to your Palm Beach mansion, true?
21 MR. PAGLIUCA: Object to the form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. Sir, it required logistical arrangements¶
1 J. Epstein - Confidential
2 for S.G. to come to your Palm Beach mansion, true?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. Who helped make the logistical arrangements
8 for S.G. to come to your Palm Beach mansion?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. Who arranged -- who made -- I'm sorry. Let
14 me strike that. Let me start over.
15 Who made the logistical arrangements for
16 S.G. to come to your Palm Beach mansion?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. Sir, isn't it true that Maxwell made the
22 logistical arrangements or assisted with the
23 logistical arrangements for S.G. to come to your Palm
24 Beach mansion?
25 MR. PAGLIUCA: Object to form and¶
1 2 3 4 5 6 7 J. Epstein - Confidential foundation. And, again, there is no good faith basis to ask this question. There are no facts supporting any inference from that question, Mr. Cassell. MR. CASSELL: I disagree with your 8 reading of the record on that. 8 MR. PAGLIUCA: Object to form. 9 BY MR. CASSELL: 9 THE WITNESS: Fifth. 10 Q. You can answer. 10 BY MR. CASSELL: 11 A. Fifth. 11 Q. Sir, isn't it true that Ms. Maxwell was 12 Q. Isn't it true that Maxwell helped to make 12 running your Palm Beach mansion in 2000? 13 the arrangements fo to come to your Palm Beach 13 MR. PAGLIUCA: Object to form and 14 mansion either directly or indirectly? 14 foundation. 15 MR. PAGLIUCA: Object to form and 15 Again, there's no evidence to suggest 16 foundation. 16 Ms. Maxwell was running anything. 17 And, again, there is no evidence 17 THE WITNESS: Fifth. 18 suggesting that that occurred with 18 BY MR. CASSELL: 19 Ms. Maxwell on being involved, and there is 19 Q. Mr. Epstein, there is lots of evidence to 20 no good faith basis to ask that question. 20 suggest that Ms. Maxwell was running your home from 21 BY MR. CASSELL: 21 1999 through about 2006. true? 22 Q. Mr. Epstein, Mr. Pagliuca just said there 22 MR. PAGLIUCA: Object to form and 23 was no good faith basis for me to ask that last 23 foundation. Argumentative. 24 question. 24 THE WITNESS: Fifth. 25 It's true, sir, that you could give us a 25¶
1 2 3 4 5 6 7 J. Epstein - Confidential 2000? MR. PAGLIUCA: Object to form. THE WITNESS: Fifth. BY MR. CASSELL: Q. Who was running your Palm Beach mansion in 2001?¶
1 J. Epstein - Confidential 1 J. Epstein - Confidential 2 very significant good faith basis for me asking that 2 BY MR. CASSELL: 3 question. isn't it? 3 Q. Sir, Miss Maxwell was running your Palm 4 MR. PAGLIUCA: Object to form and 4 Beach mansion in 2001, true? 5 foundation. 5 MR. PAGLIUCA: Object -- same 6 THE WITNESS: Fifth. 6 objections that I've raised before. This is 7 BY MR. CASSELL: 7 asked and answered. 8 Q. In fact, at that time, Maxwell was 8 MR. CASSELL: With regard to 2001 asked 9 regularly at your Palm Beach mansion, true? 9 and answered? 10 MR. PAGLIUCA: Object to form and 10 MR. PAGLIUCA: I think so. 11 foundation, and asked and answered. Same 11 THE WITNESS: Fifth. 12 objections. 12 BY MR. CASSELL: 13 THE WITNESS: Fifth. 13 Q. Sir, Ms. Maxwell was running your Palm 14 BY MR. CASSELL: 14 Beach mansion in 2002, true? 15 Q. Who was running your Palm Beach mansion in 15 MR. PAGLIUCA: Object to form and 16 2005? 16 foundation. 17 MR. PAGLIUCA: Object to form. 17 THE WITNESS: Fifth. 18 THE WITNESS: Fifth. 18 BY MR. CASSELL: 19 BY MR. CASSELL: 19 Q. Sir, Ms. Maxwell was running your Palm 20 Q. Who was running your Palm Beach mansion in 20 Beach mansion in 2003, true? 21 2006? 21 MR. PAGLIUCA: Object to form and 22 MR. PAGLIUCA: Object to form. 22 foundation. 23 THE WITNESS: Fifth. 23 THE WITNESS: Fifth. 24 BY MR. CASSELL: 24 BY MR. CASSELL: 25 Q. Who was running your Palm Beach mansion in 25 Q. Sir, Miss Maxwell was running your Palm¶
1 J. Epstein - Confidential
2 Beach mansion in 2004, true?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. Sir, Ms. Maxwell was running your Palm
8 Beach mansion in 2005, true?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. Sir, Ms. Maxwell was running your Palm
14 Beach mansion in 2006, true?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. Who had access to the financial accounts
20 for your Palm Beach mansion in 2005?
21 A. Fifth.
22 Q. Sir, isn't it true that Ms. Maxwell had
23 access to the financial accounts for your Palm Beach
24 mansion in 2005?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 VIDEO TECHNICIAN: On the record at
3 9:10 a.m.
4 MR. GOLDBERGER: Thank you for the
5 break.
6 BY MR. CASSELL:
7 Q. Sir, who did you talk to during the break?
8 A. Fifth.
9 MR. GOLDBERGER: And attorney-client.
10 MR. CASSELL: But you believe there's a
11 good faith basis for him to say what was just
12 discussed would be incriminating?
13 MR. GOLDBERGER: Objection's been
14 raised. Privileged has been invoked.
15 MR. CASSELL: All right.
16 BY MR. CASSELL:
17 Q. Without going into the substance of any
18 communications, who did you speak to during the
19 break?
20 A. Fifth.
21 MR. GOLDBERGER: Attorney-client.
22 Again, we're raising attorney-client
23 privilege without waiving any Fifth
24 Amendment privileges.
25 MR. CASSELL: Understood.¶
1 J. Epstein - Confidential
2 foundation.
3 And, again, there's no evidence to
4 suggest that Ms. Maxwell had access to
5 financial accounts of Mr. Epstein in 2005.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. Ms. Maxwell did indeed have access to some
9 of your financial accounts in 2005, true, sir?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 MR. GOLDBERGER: Mr. Cassell, can we
14 just take a 30-second break? I think I have
15 a logistical problem when I -- when I
16 connected Mr. Weinberg. I used a line that
17 was on service. So, I mean, give me two
18 seconds.
19 MR. CASSELL: All right. And we're
20 just going to confer for a moment, if that's
21 all right.
22 MR. GOLDBERGER: Thank you.
23 VIDEO TECHNICIAN: Off the record at
24 9:04 a.m.
25 (A recess was taken.)¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. You know who Alfredo Rodriguez is, sir,
4 true?
5 A. Fifth.
6 Q. Who is Alfredo Rodriguez?
7 A. Fifth.
8 Q. Alfredo Rodriguez was involved in some
9 household management issues in your Palm Beach
10 mansion in 2005, true?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. What did Alfredo Rodriguez do for you in
16 2005?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. Who did Alfredo Rodriguez report to in
22 2005?
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Sir, isn't it true that Alfredo Rodriguez
4 reported to Maxwell in 2005?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 There's no evidence to suggest that he
8 reported to Ms. Maxwell.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. Who is [REDACTED]?
12 A. Fifth.
13 Q. You know [REDACTED], don't you?
14 A. Fifth.
15 Q. What did [REDACTED] do for you at your
16 Palm Beach mansion?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. Did Alfredo Rodriguez work for you in 2005?
22 A. Fifth.
23 Q. How many years did Alfredo Rodriguez work
24 for you?
25 A. Fifth.¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. [REDACTED] and Ghislaine Maxwell both
7 assisted in the solicitation of [REDACTED] true?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 Again, there is no evidence to suggest
11 that that's true.
12 And, Mr. Cassell, if you have some good
13 faith basis and you want to put it on the
14 record, that's fine. I have the Palm Beach
15 Police Department reports here. We deposed
16 Detective Racari. You know, as well as I
17 do, that there's no evidence to suggest that
18 Ms. Maxwell was involved with [REDACTED] at all.
19 MR. CASSELL: I move to strike the
20 speaking objections. They're improper in
21 this deposition. And there's a time and a
22 place to put on both your point of views on
23 these issues and, of course, our point of
24 view as well.
25 MR. PAGLIUCA: Well, that's fine. You¶
1 Page 51
2 J. Epstein - Confidential
3 Q. [REDACTED] reported to Maxwell, true?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 There's no evidence to suggest that
7 Miss [REDACTED] reported to Miss Maxwell.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Mr. Epstein, you could give us lots of
11 evidence that [REDACTED] reported to Maxwell, true?
12 MR. PAGLIUCA: Object to form.
13 Foundation. Argumentative.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. [REDACTED] and Ghislaine Maxwell both
17 assisted you in the solicitation of S.G., true?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 And, again, there's no evidence to show
21 that Miss Maxwell participated in the
22 solicitation of anybody.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. Please give us all the evidence that
Maxwell participated in the solicitation of minors.¶
1 Page 53
2 J. Epstein - Confidential
3 know, if we can understand that my form and
4 foundation objection encompasses what you're
5 deeming as speaking objections, I can
6 certainly truncate this and just make my
7 form and foundation objections.
8 MR. CASSELL: My understanding of the
9 proper procedure is, you should object on
10 form and foundation unless I ask for further
11 clarification. That's all you need to make
12 the record.
13 MR. PAGLIUCA: Okay. And that form and
14 foundation objection, then, would include my
15 position that there's no good faith basis to
16 be asking these questions; is that correct?
17 MR. CASSELL: That's correct. That
18 would be your position. And of course, our
19 position would be to the contrary.
20 MR. PAGLIUCA: I understand. I'm just
21 trying to make sure that we're not waiving
22 anything, and I'm happy just to --
23 MR. CASSELL: Sure.
24 MR. PAGLIUCA: -- simply to object to
25 form and foundation, preserving any
objections I have to the questioning and the¶
Page 54¶
1 J. Epstein - Confidential
2 process of the proceeding. Fair?
3 MR. CASSELL: You would be preserving,
4 obviously, a form objection and a foundation
5 objection.
6 MR. PAGLIUCA: Sure. I guess the
7 questions then becomes what does that mean.
8 MR. CASSELL: Right.
9 MR. PAGLIUCA: So I can keep objecting,
10 as I am, or we can have some agreement. But
11 why don't we keep going and we'll see what
12 happens.
13 MR. CASSELL: Right. And I -- it would
14 be my position that anything beyond form and
15 foundation should be stricken.
16 MR. PAGLIUCA: Okay.
17 MR. CASSELL: Unless you can -- and
18 that's -- that's the way to proceed.
19 (Plaintiff's Exhibit JE1, Transcript of the
20 deposition of Ms. Maxwell taken on April 22nd, 2016
21 was marked for identification.)
22 BY MR. CASSELL:
23 Q. All right. Sir, I want to hand you a
24 document, which I'm document I'm going to mark as JE1
25 for Jeffrey Epstein 1. And I'll represent and¶
Page 55¶
1 J. Epstein - Confidential
2 provided a copy to both Mr. Goldberger and
3 Mr. Pagliuca. I represent that this is a transcript
4 of the deposition of Ms. Maxwell taken on April 22nd,
5 2016.
6 You have that document in front of you,
7 sir?
8 A. Yes.
9 Q. If I could ask you to flip to page 100.
10 And since there are two sets of numbers, this would
11 be the smaller set of numbers up on the, for example,
12 the top of the page. These -- these are four pages
13 per page. And page 100. I'd like to direct your
14 attention to page 100, line 8. Actually, I'm sorry,
15 page 100, line 10.
16 Do you see where I am, sir?
17 A. Yes.
18 Q. On line 10 there is a question: "Did
19 Jeffrey -- was it Jeffrey's preference to start a
20 massage with sex?"
21 Do you see that question, sir?
22 A. Yes.
23 Q. And then if we skip over two lines where
24 there's a form and foundation objection, we go to
25 line 14 where there is an answer given by¶
Page 56¶
1 J. Epstein - Confidential
2 Ms. Maxwell.
3 Do you see that answer?
4 A. Yes.
5 Q. The answer is, "I think you should ask that
6 question of Jeffrey."
7 Do you see that answer?
8 A. Yes.
9 Q. So following up on Ms. Maxwell's
10 suggestion, I'm going to ask you the same question.
11 Was it your preference to start a massage
12 with sex?
13 A. Fifth.
14 Q. It is true that your preference was to
15 start a massage with sex?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. I don't know that I completely finished the
21 question. So let me just re-ask it.
22 It is true that your preference was to
23 start a massage with sex, correct?
24 MR. PAGLIUCA: Objection to form and
25 foundation.¶
Page 57¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. To your knowledge, when she was deposed on
5 April 22nd, 2016, Maxwell knew that your preference
6 was to start a massage with sex, true?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. It is true that you directed Maxwell to
12 recruit girls under the age of 18 who would have sex
13 with you all under the guise of providing a massage,
14 correct?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. One of the girls under the age of 18 with
20 whom you had massages starting with sex was Virginia,
21 true?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.¶
1 2 3 4 5 6 7 8 9 10 11 12 J. Epstein - Confidential BY MR. CASSELL: Q. Maxwell has been present many times when you have had massages starting with sex, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. All right. Now. I want to go in the same exhibit, a little further in at page 146. All right. On page 146, line 22, do you see line 22 on page 146? 13 A. Yes. 13 Q. Can you think of any other purpose which an 15 "So would Virginia be brought on trips that were for 15 at that time, sir? 16 the purpose of work and decorating the house?" 16 MR. PAGLIUCA: Object to form and 17 Do you see that question? 17 foundation. 18 A. Yes. 18 THE WITNESS: Fifth. 19 Q. And then do you see following on 19 BY MR. CASSELL: 21 said, I never worked with her, but you would have to 21 Virginia being there at that time other than sex, 22 ask Jeffrey what he brought her on the trip for." 22 true? 23 Do you see that answer? 23 MR. PAGLIUCA: Object to form and 24 A. Yes. 24 foundation. 25 Q. And so I represent to you that that's an 25 THE WITNESS: Fifth.¶
2 3 4 5 6 7 8 9 10 11 12 J. Epstein - Confidential Virginia there for sexual purposes? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Maxwell was fully aware that Virginia was in New Mexico for sexual purposes, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: 14 Q. And do you see a question there that reads. 14 attractive 17-year-old girl would be on your property 20 immediately the answer from Ms. Maxwell: "Like I 20 Q. Maxwell knew there was no other purpose for¶
1 J. Epstein - Confidential 1 J. Epstein - Confidential 2 answer from Ms. Maxwell, and will you understand that 2 BY MR. CASSELL: 3 as I ask further questions with regard to this 3 Q. Is there anyone else I can talk to besides 5 A. Yes. 5 why Virginia was at your ranch in New Mexico? 6 Q. So following up on Ms. Maxwell's direction, 6 MR. PAGLIUCA: Object to form and 7 I would like to ask you. why did you bring -- bring 7 foundation. 8 Virginia on the trip to New Mexico? 8 THE WITNESS: Fifth. 9 MR. PAGLIUCA: Object to form and 9 BY MR. CASSELL: 10 foundation. 10 Q. There is no one else I can talk to you 11 THE WITNESS: Fifth. 11 besides you, Virginia, and Maxwell to get exact 12 BY MR. CASSELL: 12 information about why Virginia was at your ranch in 13 Q. You did bring Virginia on a trip to New 13 New Mexico, true? 14 Mexico, true, sir? 14 MR. PAGLIUCA: Object to form and 15 MR. PAGLIUCA: Object to foundation. 15 foundation. 16 THE WITNESS: Fifth. 16 THE WITNESS: Fifth. 17 BY MR. CASSELL: 17 BY MR. CASSELL: 18 Q. Why did you bring Virginia on your trips 18 Q. Let's go now to page -- actually, let me 19 with you? 19 ask one quick question while I'm thinking about it, 20 MR. PAGLIUCA: Object to form and 20 or I'll come back to that in a moment. 21 foundation. 21 Let's go to page 196. You see on line 3 of 22 THE WITNESS: Fifth. 22 196 you see a uestion: "What has Jeffrey told you 23 BY MR. CASSELL: 23 about 24 Q. With regard to the New Mexico trip that 24 Do you see that, sir? 25 we're discussing here, isn't it true that you brought 25 A. Yes.¶
4 transcript? 4 you, Virginia, and Maxwell to give information about¶
1 J. Epstein - Confidential
2 Q. And then there's an answer in line 5. Do
3 you see that?
4 A. Yes.
5 Q. The answer is that "She is a liar."
6 Do you see -- is -- I represent to you that
7 that is Ms. Maxwell stating that you said Virginia
8 [REDACTED] is a liar.
9 Is that accurate testimony from
10 Ms. Maxwell?
11 A. Fifth.
12 Q. On line 6, that's not accurate testimony
13 from Ms. Maxwell, is it?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Sorry. Repeat the
17 question.
18 BY MR. CASSELL:
19 Q. It is not accurate testimony what we see on
20 line 5 there, is it?
21 A. You said, "line 6," I believe, sir.
22 Q. I'm sorry. Let me --
23 A. Sorry.
24 Q. Yeah. Let's --
25 So you see a question on line 3, correct,¶
1 J. Epstein - Confidential
2 Do you see that question?
3 A. Yes.
4 Q. And then skipping over a form and
5 foundation objection, on line 9 we see an answer from
6 Maxwell, "You would have to check with him."
7 Do you see that?
8 A. That's incomplete, but, yes.
9 Q. And then the sentence carries on, "I can
10 tell you why I think she is a liar. I'm happy to do
11 that."
12 Do you see the rest of that?
13 A. Yes.
14 Q. But I want to focus in on the first part of
15 that sentence, "You would have to check with him."
16 Do you see that answer?
17 A. Yes.
18 Q. And that answer, you understand in context
19 to be a request from Maxwell that we check with you?
20 Do you understand that?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. So I would like to check with you now.¶
Page 63¶
1 J. Epstein - Confidential
2 sir?
3 A. Yes.
4 Q. And the question on line 3 is, "What has
5 Jeffrey Epstein told you about [REDACTED]?"
6 That's the question there?
7 A. Yes.
8 Q. And on line 5 there's an answer from
9 Ms. Maxwell that "She is a liar."
10 Do you see that answer?
11 A. Yes.
12 Q. That answer is not accurate testimony, is
13 it, sir?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. When Ms. Maxwell gave that testimony, she
19 well knew that Virginia was not a liar, true?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. Going now to line 6 there is a question,
25 "What does he base that on?"¶
Page 65¶
1 J. Epstein - Confidential
2 What do you base your assessment of
3 [REDACTED] credibility on?
4 A. Fifth.
5 Q. It's true, sir, that Virginia is highly
6 credible, isn't it?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. When Virginia has said you were a sex
12 trafficker, that's a true statement, right, sir?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. When Virginia has said that you had
18 sexually abused her, that's a true statement, isn't
19 it, sir?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. And when Virginia said Maxwell sexually
25 abused her, you know that to be a true statement as¶
1 J. Epstein - Confidential
2 well, don't you?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. Virginia has told the truth about you using
8 Maxwell to recruit girls for you to sexually abuse,
9 true, sir?
10 MR. PAGLIUCA: Objection to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. Please give us all the information that you
15 have regarding how credible Virginia is.
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. Please give us all information you have
21 about Virginia's credibility on issues relating to
22 sex abuse.
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 about threesomes between you, Maxwell, and her would
3 be the three of you, correct?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. And when I refer -- refer to "a threesome"
9 in today's deposition, will you understand that I'm
10 referring to sexual activity among three people
11 occurring essentially simultaneously?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. What is your understanding of the term
17 "threesome"?
18 A. Fifth.
19 Q. Without regard to any conduct that you may
20 or not have undertaken in the past, what do you
21 understand the word "threesome" to mean?
22 A. Fifth.
23 Q. Let's now go to page 197 of the transcript.
24 █ I'm sorry. Actually, let's go to the very bottom
25 of page 196.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Please give us all information you have
4 showing that Virginia is credible about allegations
5 she's made against you.
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Please give us all the information you have
11 about how Virginia is credible with regard to her
12 allegations against Maxwell.
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. Is there anybody else that I could check
18 with besides you to follow up on Ms. Maxwell's
19 suggestion of obtaining information about Virginia's
20 credibility with regard to sexual abuse by you?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. Sir, it's true that the only one who knows¶
1 J. Epstein - Confidential
2 Do you see line 25 on page 196?
3 A. Yes.
4 Q. And the question is: "That's all he said
5 about Virginia?"
6 Do you see that question?
7 A. I don't see a question mark, do you?
8 Q. On line 2 of page 197?
9 A. Yes.
10 Q. And so this is a reference back to line 24
11 on page 196. Do you see line 24 on page 196?
12 A. Yes.
13 Q. And the answer there from Maxwell is, "All
14 he" -- that is Epstein in context -- "told me that
15 she is a liar."
16 Do you see that answer? Do you see the
17 answer there on line 24?
18 A. Yes.
19 Q. That is not accurate testimony, is it, sir?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. In fact, you told Ms. Maxwell that you were
25 very concerned that people would learn the truth¶
Page 70¶
1 J. Epstein - Confidential¶
2 about your activities with Virginia, true?¶
3 MR. PAGLIUCA: Object to form and¶
4 foundation.¶
5 THE WITNESS: Fifth.¶
6 BY MR. CASSELL:¶
7 Q. In fact, both you and Ms. Maxwell were very¶
8 concerned that people would learn the truth about¶
9 Virginia's allegations, true?¶
10 MR. PAGLIUCA: Object to form and¶
11 foundation.¶
12 THE WITNESS: Fifth.¶
13 BY MR. CASSELL:¶
14 Q. And you and Ms. Maxwell undertook a plan at¶
15 that point to try and undercut Virginia's¶
16 credibility, true?¶
17 MR. PAGLIUCA: Object to form and¶
18 foundation.¶
19 Can you mark those for me, Reporter,¶
20 those last three questions? Thank you.¶
21 THE WITNESS: Fifth.¶
22 BY MR. CASSELL:¶
23 Q. I'm sorry. On page 197, line 3, there's an¶
24 answer, "We went through all the lies that you have¶
25 sold to the papers and sold in general, and we have¶
Page 71¶
1 J. Epstein - Confidential¶
2 analyzed her lies and your lies and your¶
3 inappropriate behavior in detail."¶
4 Do you see that answer?¶
5 A. Yes.¶
6 Q. That is not a fair and accurate recounting¶
7 of your conversation with Maxwell, is it?¶
8 MR. PAGLIUCA: Object to form and¶
9 foundation.¶
10 THE WITNESS: Fifth.¶
11 BY MR. CASSELL:¶
12 Q. In fact, the two of you were not worried¶
13 about the lies that Virginia was telling, but the¶
14 truthful statements -- let me strike that.¶
15 In fact, you were not concerned in any way¶
16 about any lies Virginia was telling because she was¶
17 not lying, true?¶
18 MR. PAGLIUCA: Object to form and¶
19 foundation.¶
20 THE WITNESS: Fifth.¶
21 BY MR. CASSELL:¶
22 Q. You were concerned that Virginia was¶
23 telling the truth, weren't you?¶
24 MR. PAGLIUCA: Object to form and¶
25 foundation.¶
Page 72¶
1 J. Epstein - Confidential¶
2 THE WITNESS: Fifth.¶
3 BY MR. CASSELL:¶
4 Q. You never denied to Maxwell that you had¶
5 sexual relations with Virginia, did you?¶
6 MR. PAGLIUCA: Object to form and¶
7 foundation.¶
8 THE WITNESS: Fifth.¶
9 BY MR. CASSELL:¶
10 Q. And in fact, Maxwell well knew that you had¶
11 sexual relations with Virginia because she had been¶
12 with you when you were having sexual relations with¶
13 Virginia?¶
14 MR. PAGLIUCA: Object to form and¶
15 foundation.¶
16 THE WITNESS: Fifth.¶
17 BY MR. CASSELL:¶
18 Q. Let's go now to page 217 of the transcript.¶
19 If you look at line 23 on page 217, do you¶
20 see a question, "Is it an obvious -- who did lead her¶
21 up to Jeffrey's room while you were talking to her¶
22 mother?"¶
23 Do you see that question?¶
24 A. Yes.¶
25 Q. And I'll represent to you that the "her" in¶
Page 73¶
1 J. Epstein - Confidential¶
2 that question is a reference to Virginia.¶
3 Do you understand that to be the question?¶
4 A. Yes.¶
5 Q. And if we go over onto the next page, then,¶
6 we see, "Answer: You would have to ask Virginia. I¶
7 don't know if she was led up to his room."¶
8 Do you see that answer?¶
9 A. Yes.¶
10 Q. There's actually another person that we¶
11 could ask, apart from Virginia, who would know who¶
12 led her up to your room; isn't that true, sir?¶
13 MR. PAGLIUCA: Object to form and¶
14 foundation.¶
15 THE WITNESS: Fifth.¶
16 BY MR. CASSELL:¶
17 Q. The first time you met Virginia, where did¶
18 you meet her?¶
19 A. Fifth.¶
20 Q. Isn't it true that the first time you met¶
21 virgin what was in your massage room in your Palm¶
22 Beach mansion?¶
23 MR. PAGLIUCA: Object to form and¶
24 foundation.¶
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Isn't it true that Maxwell led Virginia up
4 to your Palm Beach mansion massage room the first
5 time you met her?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. You saw Maxwell bringing Virginia up to
11 your room, true, sir?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. Isn't it true that it was standard
17 operating procedure for Maxwell to bring underage
18 girls up to your room?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Isn't it true that it was standard
24 operating procedure for Maxwell to bring underage
25 girls up to your room for you to sexually abuse?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. Isn't it true that Maxwell's sworn
7 testimony is inaccurate when she says she didn't
8 bring Virginia up to your room?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. Isn't it true that Maxwell was perjuring
14 herself when she said she didn't know who brought
15 Virginia up to your room?
16 MR. PAGLIUCA: Object to form
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. Let's go now to page 229 of the transcript,
21 line 11.
22 Do you see the question there, "So not the
23 first time she came but the second time she came or
24 the third time or any time she came, did you ever
25 participate in a massage with her in¶
1 J. Epstein - Confidential
2 Jeffrey Epstein's room?"
3 Do you see that question?
4 A. Yes.
5 Q. And then you see an answer there, "I have
6 never participated at any time with Virginia in a
7 massage with Jeffrey."
8 Do you see that answer?
9 A. Yes.
10 Q. And I represent to you the answer is being
11 given by Ms. Maxwell during a sworn deposition. Will
12 you understand that with regard to my questions here?
13 A. Yes.
14 Q. Miss Maxwell's testimony is not truthful,
15 is it, sir?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. In fact, you, Maxwell, and Virginia all had
21 sexual contact together at the same time on multiple
22 occasions, true?
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. How many times have you, Maxwell, and
4 Virginia had sexual contact together?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. On multiple occasions you and Maxwell
10 jointly participated in sexual abuse of Virginia,
11 true?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. Have you and Maxwell ever jointly
17 participated in the sexual abuse of Virginia?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. How many times have you and Maxwell jointly
23 participated in the sexual abuse of Virginia?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
Page 78¶
1 J. Epstein - Confidential¶
2 THE WITNESS: Fifth.¶
3 BY MR. CASSELL:¶
4 Q. Your understanding of all the facts in this¶
5 case is that Maxwell was lying when she denied sexual¶
6 abuse of Virginia, true?¶
7 MR. PAGLIUCA: Objection to form and¶
8 foundation.¶
9 THE WITNESS: Fifth.¶
10 BY MR. CASSELL:¶
11 Q. If Maxwell had told the truth in her¶
12 deposition, she would have admitted to sexually¶
13 abusing Virginia, true?¶
14 MR. PAGLIUCA: Objection to form and¶
15 foundation.¶
16 THE WITNESS: Fifth.¶
17 BY MR. CASSELL:¶
18 Q. When you and Maxwell were jointly sexually¶
19 abusing Virginia, who were the witnesses to that¶
20 activity?¶
21 MR. PAGLIUCA: Object to form and¶
22 foundation.¶
23 THE WITNESS: Fifth.¶
24 BY MR. CASSELL:¶
25 Q. It's true, sir, that when you and Maxwell¶
Page 79¶
1 J. Epstein - Confidential¶
2 were jointly sexually abusing Virginia, you two were¶
3 the only two witnesses who could see what was going¶
4 on?¶
5 MR. PAGLIUCA: Object to form and¶
6 foundation.¶
7 THE WITNESS: Fifth.¶
8 BY MR. CASSELL:¶
9 Q. Are there any other witnesses I should call¶
10 to try to depose and talk to to see whether you and¶
11 Maxwell were jointly sexually abusing Virginia?¶
12 MR. PAGLIUCA: Object to form and¶
13 foundation.¶
14 THE WITNESS: Fifth.¶
15 BY MR. CASSELL:¶
16 Q. How many times did you and Maxwell have sex¶
17 with Virginia?¶
18 MR. PAGLIUCA: Object to form and¶
19 foundation.¶
20 THE WITNESS: Fifth.¶
21 BY MR. CASSELL:¶
22 Q. How many times did you have sex with¶
23 Virginia?¶
24 MR. PAGLIUCA: Object to form and¶
Page 80¶
1 J. Epstein - Confidential¶
2 foundation.¶
3 THE WITNESS: Fifth.¶
4 BY MR. CASSELL:¶
5 Q. How many times, to your knowledge, did¶
6 Maxwell have sex with Virginia?¶
7 MR. PAGLIUCA: Object to form and¶
8 foundation.¶
9 THE WITNESS: Fifth.¶
10 BY MR. CASSELL:¶
11 Q. Sir, it's true that you had sex with¶
12 Virginia dozens if not hundreds of times; isn't that¶
13 true?¶
14 MR. PAGLIUCA: Object to form and¶
15 foundation.¶
16 THE WITNESS: Fifth.¶
17 BY MR. CASSELL:¶
18 Q. And to your knowledge, Maxwell had sex with¶
19 Virginia dozens and dozens of times, true?¶
20 MR. PAGLIUCA: Objection to form and¶
21 foundation.¶
22 THE WITNESS: Fifth.¶
23 BY MR. CASSELL:¶
24 Q. What years did you and Maxwell have sex¶
25 with Virginia?¶
Page 81¶
1 J. Epstein - Confidential¶
2 MR. PAGLIUCA: Object to form and¶
3 foundation.¶
4 THE WITNESS: Fifth.¶
5 BY MR. CASSELL:¶
6 Q. It's true that you and Maxwell had sex with¶
7 Virginia in the year 2000, true?¶
8 MR. PAGLIUCA: Object to form and¶
9 foundation.¶
10 THE WITNESS: Fifth.¶
11 BY MR. CASSELL:¶
12 Q. It's true that you and Maxwell had sex with¶
13 Virginia in the year 2001, true?¶
14 MR. PAGLIUCA: Object to form and¶
15 foundation.¶
16 THE WITNESS: Fifth.¶
17 BY MR. CASSELL:¶
18 Q. You had sex with Virginia repeatedly when¶
19 she was under the age of 18, true?¶
20 MR. PAGLIUCA: Object to form and¶
21 foundation.¶
22 THE WITNESS: Fifth.¶
23 BY MR. CASSELL:¶
24 Q. You also had sex with Virginia when she was¶
25 under the age of 17, true?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. You had sex with Virginia when she was
7 16 years old, true?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. Maxwell had sex with Virginia when she was
13 16, true?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Maxwell had sex with Virginia when she was
19 17, true?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 MR. CASSELL: If I could just confer
24 with counsel for a moment.
25 (A discussion was held off the record.)¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. You have a sexual preference for having sex
4 with girls between the ages of 12 to 17, true?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. Between 2000 and 2005, you sexually abused
10 more than 100 girls under the age of 18 in Florida,
11 true?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. Between 2000 and 2005, you also sexually
17 abused dozens of girls in other locations as well,
18 true?
19 MR. PAGLIUCA: Objection to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. In about 2002, you and Maxwell asked
24 Virginia to carry a baby for the two of you, true?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. When you asked Virginia to carry a baby for
6 you, part of your proposal was for her to turn the
7 baby over to the two of youth -- to the two of you at
8 the end of the pregnancy, true?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. In about June or July of 2001, you and
14 Maxwell took Virginia to a hospital in New York City
15 because of a problem she was having with vaginal
16 bleeding, true?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. When you and Maxwell took Virginia to the
22 hospital, the two of you lied to the hospital to make
23 her age 18 rather than 17, true?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. You and Maxwell have had so-called
5 threesomes, i.e., sexual activity with three people
6 at the same time, with multiple girls who were under
7 the age of 18, true?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. Many of these threesomes occurred in
13 Florida, true?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. You and Maxwell have also participated in
19 sex orgies with Virginia, true?
20 MR. PAGLIUCA: Objection to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. You and Maxwell participated in sex orgies
25 with Virginia while she was under the age of 18,¶
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 J. Epstein - Confidential true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You and Maxwell participated in sex orgies with many other girls, true? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. THE COURT REPORTER: Excuse me. Can we go off the record? I'm sorry. VIDEO TECHNICIAN: Off the record at 9:39 a.m. (A discussion was held off the record.) VIDEO TECHNICIAN: On the record at 9:41. BY MR. CASSELL: Q. Sir, without regard to any conduct that you may or may not have committed, what do you understand the word "orgy" to mean? A. Fifth. Q. Sir, in the summer of 2000. you first met Miss in your Palm Beach mansion.¶
1 .I. Epstein - Confidential 2 true? 3 MR. PAGLIUCA: Object to form and 4 foundation. 5 THE WITNESS: Fifth. 6 BY MR. CASSELL: 7 Q. Ms. Maxwell was the person who first 8 introduced you to Virginia, true? 9 MR. PAGLIUCA: Object to form and 10 foundation. 11 THE WITNESS: Fifth. 12 BY MR. CASSELL: 13 Q. At the time, Virginia was just 16 years 14 old, true? 15 MR. PAGLIUCA: Object to form and 16 foundation. 17 THE WITNESS: Fifth. 18 BY MR. CASSELL: 19 Q. When you first met Miss -- and I 20 guess I'll refer to as Virginia for the rest of these 21 questions -- her physical appearance to you was that 22 she was only 16 years old, true? 23 MR. PAGLIUCA: Object to form and 24 foundation. 25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential 2 BY MR. CASSELL: 3 Q. The reason Maxwell introduced Virginia to 4 you was so that you could have sex with Virginia. 5 true? 6 MR. PAGLIUCA: Object to form and 7 foundation. 8 THE WITNESS: Fifth. 9 BY MR. CASSELL: 10 Q. In fact, on a number of occasions in 2000 11 and 2001, both you and Maxwell simultaneously had %ex 12 with Virginia, true? 13 MR. PAGLIUCA: Object to form and 14 foundation. 15 THE WITNESS: Fifth. 16 BY MR. CASSELL: 17 Q. Without going into detail, please describe 18 the nature of the sex acts that you performed on 19 Virginia in 2000 and 2001? 20 MR. PAGLIUCA: Object to form and 21 foundation. 22 THE WITNESS: Fifth. 23 BY MR. CASSELL: 24 Q. Without going into detail, please describe 25 the nature of the sex acts that you observed Maxwell¶
1 J. Epstein - Confidential 2 perform on Virginia in 2000 and 2001. 3 MR. PAGLIUCA: Object to form and 4 foundation. 5 THE WITNESS: Fifth. 6 BY MR. CASSELL: 7 Q. In the fall of 2000, you and Maxwell 8 trained Virginia on how to cater to the sexual 9 desires of your male friends, true? 10 MR. PAGLIUCA: Object to form and 11 foundation. 12 THE WITNESS: Fifth. 13 BY MR. CASSELL: 14 Q. And from 2000 through 2002, you forced 15 Virginia to interact sexually with many of your male 16 friends. true? 17 MR. PAGLIUCA: Object to form and 18 foundation. 19 THE WITNESS: Fifth. 20 BY MR. CASSELL: 21 Q. From 2000 through 2001, you forced Virginia 22 to sexually interact with Harvard Law Professor. 23 Alan Dershowitz? 24 MR. PAGLIUCA: Object to form and 25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. It would be a fair statement to describe
5 Virginia's situation from the fall of 2000 through
6 July 2001 as your sex slave, true?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. You understand the term "sex slave," don't
12 you, sir?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. Without to regard to any conduct that you
18 may or may not have committed, what does the term
19 "sex slave" mean to you?
20 A. Fifth.
21 (Plaintiff's Exhibit JE2, Document with
22 titles of books was marked for identification.)
23 BY MR. CASSELL:
24 Q. I'm going to show you what I'll mark as
25 JE2.¶
1 J. Epstein - Confidential
2 true?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. You relied on the Defendant in this case,
8 Ghislaine Maxwell, to keep Virginia available for to
9 you sexually abuse, true?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Are we finished with
13 this?
14 BY MR. CASSELL:
15 Q. Yes.
16 MR. CASSELL: Did we get an answer to
17 -- to that?
18 MR. PAGLIUCA: Yes, you did. We did
19 not?
20 MR. GOLDBERGER: Yes. I thought he
21 said the Fifth.
22 BY MR. CASSELL:
23 Q. Let me just re-ask the question, because
24 it's an important one.
25 Sir, you relayed on the Defendant in this¶
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1 J. Epstein - Confidential
2 A. Are you finished with this?
3 Q. Yeah. We're through with that now.
4 You recognize the books listed on this
5 document, don't you, sir?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. The first book listed here as being sold by
11 Amazon is "Slave Craft: Road Maps For Erotic
12 Servitude, Principles, Skills, and Tools."
13 Do you see that, sir?
14 A. Yes.
15 Q. That was a book you ordered, sir, true?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. The second book listed here is "Training
21 With Ms. Abernathy. A Workbook For Erotic Slaves and
22 Their Owners."
23 Do you see that there, sir?
24 A. Yes.
25 Q. That was another book that you ordered,¶
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1 J. Epstein - Confidential
2 case, Ms. Maxwell, to keep Virginia available --
3 available for you to sexually abuse, true?
4 MR. PAGLIUCA: Objection to the form
5 and foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. What did Miss Maxwell do for you in the
9 years 2001 and 2001?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. Please briefly describe the nature of the
15 interactions you observed between the Defendant in
16 this case, Ms. Maxwell, and the Plaintiff in this
17 case. [REDACTED]
18 [REDACTED], from the fall of 2000 through the
19 summer of 2001.
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. The reason you're taking the Fifth, with
25 regard to Maxwell's interactions, is that she was¶
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1 J. Epstein - Confidential
2 involved in the sexual abuse of Virginia, true?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. Please describe the massage room upstairs
8 in your Palm Beach mansion.
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. It's true, sir, that you do have a massage
14 room upstairs in your Palm Beach mansion, right?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. What kinds of rooms do you have upstairs in
20 your Palm Beach mansion?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. In that massage room, Maxwell kept a basket¶
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1 J. Epstein - Confidential
2 of sex toys, true?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. And if we narrow the time frame down to the
8 years 2000 and 2001, Maxwell had a basket of sex toys
9 there, true?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. Maxwell used sex toys on Virginia in your
15 presence, true?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. What is your understanding of the term "sex
21 toy" without regard to any conduct that you may or
22 may not have committed in the past?
23 A. Fifth.
24 Q. Before August 2001, Maxwell forcibly
25 penetrated Virginia with an artificial penis or dildo¶
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1 J. Epstein - Confidential
2 in your presence, true?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. You and Maxwell flew together with Virginia
8 over 20 times when Virginia was under the age of 18,
9 true?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. How many times did you and Maxwell fly
15 together with Virginia before August of 2001?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. You and Maxwell trafficked Virginia while
21 she was under the age of 17 to other men for sexual
22 purposes, true?
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 THE WITNESS: Fifth.¶
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1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. During the period of time 2000 to 2001, you
4 were having sex as many as three times a day, true?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. And during that time period, Maxwell was
10 bringing girls to you to take the pressure off her to
11 have that much sex, true?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. You and Maxwell asked girls under the age
17 of 18 to bring other girls under the age of 18 to you
18 for sexual purposes, true?
19 MR. PAGLIUCA: Objection to form and
20 foundation.
21 THE WITNESS: Fifth.
22 Can I have some water?
23 MR. CASSELL: Uh-huh.
24 BY MR. CASSELL:
25 Q. Maxwell was in charge of coordinating the¶
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1 J. Epstein - Confidential
2 girls who came to your house for sexual purposes,
3 true?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. Maxwell and your house staff used message
9 pads to coordinate the schedule for the girls coming
10 over to your houses, true?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. Maxwell often paid the girls who came over
16 to your house for sexual purposes, true?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. Who paid the girls who came over to your
22 house for sexual purposes?
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 THE WITNESS: Fifth.¶
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1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Maxwell used the prospect that girls could
4 become models for Victoria's Secret to lure them over
5 to your house, true?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. How did you lure girls over to your house
11 for sexual purposes?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. What techniques did you see Maxwell using
17 to lure girls over to your house for sexual purposes?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. On or about March 9th, 2001, you, the
23 Defendant in this case, Ms. Maxwell, Emmie Taylor,
24 and Virginia flew on your private jet from Tangiers
25 to Luton International Airport in the London, England¶
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1 J. Epstein - Confidential
2 metropolitan area?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. On that trip you stayed in London at
8 Maxwell's flat, true?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. At that time, it would be a fair assessment
14 to say that Maxwell was your girlfriend, true?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. In March of 2001, who was your girlfriend?
20 A. Fifth.
21 Q. During that trip, in March of 2001,
22 Maxwell, Virginia, and Prince Andrew, that is, the
23 [REDACTED] of York, all met at night inside Maxwell's flat,
24 true?
25 MR. PAGLIUCA: Object to form and¶
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1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. Did you meet Prince Andrew, the [REDACTED] of
6 York, in about March of 2001 in London?
7 A. Fifth.
8 MR. CASSELL: I guess we'll mark this
9 as JE3.
10 (Plaintiff's Exhibit JE3, Photograph
11 depicting Prince Andrew, Maxwell, and Virginia was
12 marked for identification.)
13 MR. CASSELL: I've got copies for
14 opposing counsel here.
15 MR. GOLDBERGER: Thank you.
16 BY MR. CASSELL:
17 Q. Showing you what's been marked as JE3. Do
18 you have that in front of you, sir?
19 A. Yes.
20 Q. Do you recognize that photograph?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. Sir, this is a photograph depicting¶
1 J. Epstein - Confidential
2 Prince Andrew, Maxwell, and Virginia all together,
3 true?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. You took this photograph, right, sir?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. Who took this photograph?
14 A. Fifth.
15 Q. If you look at the person on the left, the
16 male figure in the photograph, do you see that person
17 there?
18 A. Yes.
19 Q. That person has his arm around the bare
20 midriff of a young girl, true?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Yes.
24 BY MR. PAGLIUCA:
25 Q. That's Prince Andrew's arm around the waist¶
1 J. Epstein - Confidential
2 of Virginia touching her bare midriff, true?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. The only persons inside of Maxwell's flat
8 at this time, in addition to you and Maxwell, were
9 Virginia and Prince Andrew, true?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. Where was this photograph taken?
15 MR. PAGLIUCA: Object to foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. This photograph was taken in Maxwell's flat
19 in London, true?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. You immediately recognized where this
25 picture was taken, didn't you, sir?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. And based on your understanding of the
7 circumstances surround the taking -- surrounding the
8 taking of this photograph, Ms. Maxwell would have
9 immediately identified who was in this photograph and
10 where it was taken, true?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Could you repeat that
14 question? I'm sorry. Could you repeat that
15 question?
16 BY MR. CASSELL:
17 Q. And based on your understanding of the
18 circumstances surrounding the taking of this
19 photograph, Ms. Maxwell would have immediately
20 identified who was in this photograph, true?
21 MR. PAGLIUCA: Same objection.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. And based on your understanding of the
25 circumstances surrounding the taking of this¶
1 J. Epstein - Confidential
2 photograph, Ms. Maxwell would have immediately
3 identified where this photograph was taken, true?
4 MR. PAGLIUCA: Same objection.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. The only persons -- I think we may have
8 already asked this. Let's see. Let me just ask this
9 to make sure.
10 The only persons inside of Maxwell's flat
11 at that time, in addition to you and Maxwell, were
12 Virginia and Prince Andrew, true?
13 MR. PAGLIUCA: Form -- form and
14 foundation. Asked and answered.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. Prince Andrew's security detail remained
18 outside of Maxwell's flat when this photograph was
19 taken, true?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. Shortly after this photograph was taken,
25 you and Maxwell both observed Prince Andrew and¶
1 J. Epstein - Confidential
2 Virginia go into the room depicted in the back of the
3 photograph, true?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. And in this photograph, you do see a room
9 depicted in the back?
10 A. Fifth.
11 Q. You're taking the Fifth about what is shown
12 in this photograph?
13 A. I -- I can't see anything. I'm sorry.
14 MR. GOLDBERGER: Okay. So it's -- so
15 we're not -- we're not raising Fifth
16 Amendment privilege.
17 You cannot -- your answer is, you
18 cannot see what Mr. Cassell is referring to?
19 THE WITNESS: Correct.
20 MR. GOLDBERGER: Okay.
21 BY MR. CASSELL:
22 Q. Do you see a window depicted in this
23 photograph?
24 A. I don't know what it is. I'm sorry.
25 Q. Do you see a [REDACTED] light reflecting off of¶
1 J. Epstein - Confidential
2 a blue surface in this photograph?
3 A. Yes.
4 Q. Does that appear to you to be a window?
5 A. Not necessarily, no.
6 MR. GOLDBERGER: Why don't you just
7 assume arguendo that -- that that -- what --
8 what you're trying to have Mr. Epstein
9 identify is a room, and then we can go on
10 from there.
11 MR. CASSELL: All right.
12 BY MR. CASSELL:
13 Q. That room is a bedroom in Ms. Maxwell's
14 flat, true?
15 MR. PAGLIUCA: Object to the form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. You and Maxwell instructed Virginia to have
20 sex with Prince Andrew, true?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. In fact, it would be a fair assessment of¶
1 J. Epstein - Confidential
2 all the circumstances surrounding this situation to
3 say that you forced Virginia to have sex with
4 Prince Andrew?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. What would have happened to Virginia if she
10 had refused to have sex with Prince Andrew?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. At the time Virginia retired to the bedroom
16 with Prince Andrew, Maxwell was in possession and
17 control of Virginia's U.S. pass -- passport, true?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. Who had Virginia's passport when she
23 entered England?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. After she was inside of English territory,
5 who main con- -- remained in control of her passport?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Virginia was 17 years old at this time,
11 true?
12 A. Fifth.
13 MR. PAGLIUCA: Objeject to form and
14 foundation.
15 THE WITNESS: Sorry. Fifth.
16 BY MR. CASSELL:
17 Q. It was your understanding that
18 Prince Andrew and Virginia was retiring to this
19 bedroom to have sex, true?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. What did you understand Virginia and
25 Prince Andrew to be doing that evening?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. Shortly after Prince Andrew and Virginia
6 had sex, Virginia gave you a full report about the
7 details of the sex, true?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. Did Virginia tell you anything after this
13 photograph was taken about Prince Andrew?
14 MR. PAGLIUCA: Object to foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. Did Prince Andrew tell you anything about
18 what he had done with Virginia in the room?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Isn't it true, sir, that Prince Andrew
24 thanked you for making Virginia available to him for
25 sexual purposes?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. You had previously instructed Virginia that
7 she had to give you a full report on the details of
8 what men like Prince Andrew did to her so that you
9 would have blackmail material you could use, true?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. What instructions, if any, had you given to
15 Virginia about what she should say after she had sex
16 with men?
17 MR. PAGLIUCA: Object to foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. What did you do with the information that
21 Virginia gave you after she had sex with men?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. What, if anything, did you do with the
4 information that Virginia gave you after you had
5 sex -- after she had sex with men?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Approximately the next day after this
11 photograph was taken, you made Virginia report to you
12 in detail about Prince Andrew's sexual preferences,
13 true?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. What, if anything, do you know about
19 Prince Andrew's sexual preferences?
20 MR. PAGLIUCA: Object to foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. We can go into the details if this would
24 help refresh your memory, but isn't it true that
25 Virginia recounted specific behavior that¶
1 J. Epstein - Confidential
2 Prince Andrew requested before sexual intercourse?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. The reason you asked for a detailed review
8 of Prince Andrew's sexual activities was so that you
9 would have blackmail information about him, true?
10 MR. PAGLIUCA: Object to form. Asked
11 and answered.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. Why did you ask for a detailed review of
15 Prince Andrew's sexual activities?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. You had previously told Virginia it was
21 part of her job to give you detailed information
22 about the men that you and Maxwell forced her to have
23 sex with, true?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
Page 114¶
1 J. Epstein - Confidential¶
2 THE WITNESS: Fifth.¶
3 BY MR. CASSELL:¶
4 Q. When Virginia had sex with men that you¶
5 forced upon her, what was her job?¶
6 MR. PAGLIUCA: Object to form and¶
7 foundation.¶
8 THE WITNESS: Fifth.¶
9 BY MR. CASSELL:¶
10 Q. What would have happened to Virginia if she¶
11 had refused your request to have sex with men?¶
12 MR. PAGLIUCA: Objection to form and¶
13 foundation.¶
14 THE WITNESS: Fifth.¶
15 BY MR. CASSELL:¶
16 Q. Isn't it true, sir, that you would have¶
17 threatened Virginia and, in fact, potentially harmed¶
18 her if she refused to have sex with the men you¶
19 provided to her?¶
20 MR. PAGLIUCA: Object to form and¶
21 foundation.¶
22 THE WITNESS: Fifth.¶
23 BY MR. CASSELL:¶
24 Q. What kind of threats did you make against¶
25 Virginia when she was with you?¶
Page 115¶
1 J. Epstein - Confidential¶
2 MR. PAGLIUCA: Object to form and¶
3 foundation.¶
4 THE WITNESS: Fifth.¶
5 BY MR. CASSELL:¶
6 Q. Please describe all the threats you have¶
7 ever made against Virginia.¶
8 MR. PAGLIUCA: Object to form and¶
9 foundation.¶
10 THE WITNESS: Fifth.¶
11 BY MR. CASSELL:¶
12 Q. Have you every made threats against¶
13 Virginia?¶
14 A. Fifth.¶
15 Q. At one point you told Virginia that you¶
16 needed detailed sexual information from the men she¶
17 had sex with so those men would owe you favors, true?¶
18 MR. PAGLIUCA: Object to form and¶
19 foundation?¶
20 THE WITNESS: Fifth.¶
21 BY MR. CASSELL:¶
22 Q. When you provided Virginia to men to have¶
23 sex, they then did owe you favors, true?¶
24 MR. PAGLIUCA: Object to form and¶
25 foundation.¶
Page 116¶
1 J. Epstein - Confidential¶
2 THE WITNESS: Fifth.¶
3 BY MR. CASSELL:¶
4 Q. In 2000, Virginia was approached by¶
5 Maxwell, true?¶
6 MR. PAGLIUCA: Object to form and¶
7 foundation.¶
8 THE WITNESS: Fifth.¶
9 BY MR. CASSELL:¶
10 Q. Maxwell was one of the main women whom you¶
11 used to procure underage girls for sexual activities,¶
12 true?¶
13 MR. PAGLIUCA: Object to form and¶
14 foundation.¶
15 THE WITNESS: Fifth.¶
16 BY MR. CASSELL:¶
17 Q. It was your understanding that Maxwell met¶
18 Virginia at the Mar-a-Lago Club in Palm Beach in¶
19 2000, true?¶
20 MR. PAGLIUCA: Object to form and¶
21 foundation.¶
22 THE WITNESS: Fifth.¶
23 BY MR. CASSELL:¶
24 Q. In 2000, you were a member of the¶
25 Mar-a-Lago Club, true?¶
Page 117¶
1 J. Epstein - Confidential¶
2 MR. PAGLIUCA: Object to form.¶
3 THE WITNESS: Fifth.¶
4 BY MR. CASSELL:¶
5 Q. In 2000, Ms. Maxwell had access to the¶
6 Mar-a-Lago Club, true?¶
7 MR. PAGLIUCA: Object to form and¶
8 foundation.¶
9 THE WITNESS: Fifth.¶
10 BY MR. CASSELL:¶
11 Q. The reason Maxwell had access to the¶
12 Mar-a-Lago Club in 2000 was because of your¶
13 connections to the club, true?¶
14 MR. PAGLIUCA: Object to form and¶
15 foundation.¶
16 THE WITNESS: Fifth.¶
17 BY MR. CASSELL:¶
18 Q. Maxwell was a primary co-conspirator in¶
19 your sexual abuse scheme, true?¶
20 MR. PAGLIUCA: Object to form and¶
21 foundation.¶
22 THE WITNESS: Fifth.¶
23 BY MR. CASSELL:¶
24 Q. Maxwell was a primary co-conspirator in¶
25 your sex trafficking scheme, true?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. Maxwell herself regularly participated in
7 your sexual exploitation of minors, true?
8 MR. PAGLIUCA: Object to form and
9 found.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. In 2000, Maxwell herself regularly
13 participated in your sexual exploitation of minors,
14 true?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. Maxwell herself regularly participated in
20 your sexual exploitation of Virginia, true?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. Did Maxwell participate in your sexual¶
1 J. Epstein - Confidential
2 exploitation of Virginia?
3 MR. PAGLIUCA: Object to foundation.
4 THE WITNESS: Fifth.
5 Can we take a break so I can stand up?
6 MR. CASSELL: Sure.
7 VIDEO TECHNICIAN: Off the record at
8 10:01.
9 (A recess was taken.)
10 VIDEO TECHNICIAN: This is the
11 beginning of disc two. On the record at
12 10:08.
13 BY MR. CASSELL:
14 Q. Has Maxwell ever made any threats against
15 Virginia?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. It's true, sir, that Maxwell has threatened
21 Virginia, right?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Has Maxwell ever made any threats against
4 other girls that you interacted with?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. It's true, sir, that Maxwell has made
10 threats against other girls with whom you've
11 interacted?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. Has Maxwell ever told girls that they
17 should keep quiet about the sexual activities you
18 have had with them?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. It's true, sir, Maxwell has made threats
24 against girls to tell them or force -- sorry. Let me
25 to start over.¶
1 J. Epstein - Confidential
2 It's true, sir, that Maxwell has told girls
3 they should keep quiet about the sexual activities
4 you had with them, right?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. Has Maxwell ever told girls they should
10 keep quiet about the sexual activities she had with
11 them?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. It's true, sir, that Maxwell had told girls
17 they should keep quiet about the sexual activity she
18 had with them, right?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. What, if anything, did Maxwell tell
24 Virginia would happen to her if she refused your
25 demands to have sex?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. Isn't it true, sir, that Maxwell threatened
7 Virginia if she refused to have sex with you?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. Maxwell regularly participated in your
13 sexual exploitation of Virginia, true?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Maxwell persuaded Virginia to come to your
19 mansion in 2000, true?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. Virginia was 16 years old when Maxwell
25 persuaded her to come to your mansion, true?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. The fashion in which Maxwell persuaded
7 Virginia to come to your mansion was similar to the
8 manner in which you coerced dozens of other children
9 to come to your mansion, true?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. When Virginia be- -- sorry.
15 When Virginia began giving you a massage,
16 you and Maxwell turned it into a sexual encounter,
17 true?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. You had done the same thing with many other
23 victims, true?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. After you first sexually abused Virginia,
5 you became enamored with her, true?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. How did you feel about Virginia after you
11 first met her?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. With the assistance of Maxwell, you
17 converted Virginia into what is commonly referred to
18 as a sex slave, true?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. When you interacted with Virginia in 2000
24 and 2001, what were you doing with her?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. You sexually exploited Virginia from the
6 summer of 2000 through about September 2002, true?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. In 2002, Virginia managed to escape to a
12 foreign country and hide from you, true?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. In 2002, when Virginia escaped, she was
18 also hiding from Maxwell, true?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Why would Virginia have wanted to hide from
24 you in 2002?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. Virginia was hiding from you because she
6 was afraid of you, true?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. Virginia was hiding from Maxwell because
12 she was afraid of Maxwell, true?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. From 2000 through 2002, you and Maxwell
18 sexually abused Virginia in Palm Beach, Florida,
19 true?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. From 2000 through 2002, you and Maxwell
25 sexually abused Virginia in New York City, true?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. From 2000 through 2002, you and Maxwell --
7 Maxwell sexually abused Virginia in New Mexico, true?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. From 2000 through 2002, you and Maxwell
13 sexually abused Virginia in the U.S. Virgin Islands?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. From 2000 through 2002, you and Maxwell
19 sexually abused Virginia on your private jet?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. You abused Virginia other places than the
25 ones I've just mentioned, true?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. Maxwell sexually abused Virginia in places
7 other than the ones I just mentioned, true?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. Please list all the places that you had sex
13 with Virginia.
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Please list all the places where, to your
19 knowledge, Maxwell had sex with Virginia.
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. You and Maxwell sexually trafficked
25 Virginia by forcing her to have sex with politically¶
1 J. Epstein - Confidential
2 connected and financially powerful people, true?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. Your purpose in sending Virginia to such
8 powerful people was to ingratiate yourself with them,
9 true?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. Maxwell's purpose in sending Virginia to
15 such powerful people was to ingratiate herself with
16 them, true?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. The reason you and Maxwell were sending
22 Virginia to these powerful people was for business,
23 personal, political, and financial gain, true?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. Another reason was to gain potential
5 blackmail information, true?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Maxwell was fully involved in sending
11 Virginia to various powerful people for sexual
12 purposes, true?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. And Maxwell was hoping to obtain blackmail
18 information as well, true?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. You observed Maxwell sexually abuse
24 Virginia in 2000, true?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 was former -- former Harvard Law Professor,
3 Alan Dershowitz, true?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. You and Maxwell required Virginia to have
9 sexual relations with Dershowitz on numerous
10 occasions while she was a minor, true?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. You and Maxwell forced Virginia to have
16 sexual relations with Dershowitz in Florida,
17 New York, New Mexico, and the U.S. Virgin Islands,
18 among other places, true?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Please list all the places where you forced
24 Virginia to have sexual relations with Dershowitz.
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. You observed Maxwell sexually abuse
6 Virginia in 2001?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. How many times have you observed Maxwell
12 sexually abuse Virginia?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. How many times have you observed Maxwell
18 have any form of sexual interaction with Virginia?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. One powerful individual that you and
24 Maxwell forced Virginia to have sexual relations with¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. In addition to being a participant in the
6 abuse of Virginia and other minors, Dershowitz was an
7 eyewitness to the sexual abuse of many other minor
8 girls by you and Maxwell, true?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. Dershowitz was an eyewitness to the sexual
14 abuse of many other minors by you, true?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. One way to describe Maxwell's role for you
20 was as a madam, true?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. You've heard the term "madam" used in¶
Page 134¶
1 J. Epstein - Confidential
2 reference to someone who is a procurer of women or
3 other girls for sex, right?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. What was Maxwell's role for you in 2000 and
9 2001?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. What was Maxwell's role with you in 2005?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. Using the term "madam" as I had previously
20 defined it, wouldn't it be fair to say Maxwell was a
21 madam for you in 2000?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25¶
Page 135¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Wouldn't it fair to say that she was an
4 madam for you in 2001?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. Wouldn't it be fair to say that she was a
10 madam for you in 2006?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. It would be fair to say that Maxwell
16 assumed -- assumed a position of trust for the girls
17 whom you sexually abused, including Virginia, true?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. You know that Maxwell had sex with dozens
23 of underage girls, true?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
Page 136¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. Maxwell had sex with Virginia in the U.S.
5 Virgin Islands, New Mexico, New York, France, and
6 many other locations, true?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. From 2000 through 2005, what kinds of
12 pictures did you have in your Florida mansion?
13 A. Fifth.
14 Q. From 2000 through 2005, what kind of
15 pictures did you have in your New York City mansion?
16 A. Fifth.
17 Q. From 2000 to 2005, what kinds of pictures
18 did you have in the U.S. Virgin Islands' residence?
19 A. Fifth.
20 Q. Maxwell took sexually explicit pictures of
21 many underage girls, true?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25¶
Page 137¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. What kinds of pictures have you seen
4 Maxwell take?
5 MR. PAGLIUCA: Object to foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. Have you ever seen Maxwell take pictures of
9 girls under the age of 18?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. It's true, sir, that you've seen Maxwell
15 take many picture of girls under the age of 18, true?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. In fact, you displayed pictures of naked
21 girls throughout your home in Florida, true?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. In fact, you displayed pictures of naked
4 girls throughout your home in New York, true?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. In fact, you displayed pictures of naked
10 girls throughout your home in the U.S. Virgin
11 Islands, true?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. In fact, you displayed pictures of naked
17 girls throughout your home in New Mexico, true?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. Tell me about all the circumstances in
23 which you've seen Maxwell providing cameras to
24 people.
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. Please describe all the pictures of girls
7 that you've seen Maxwell take.
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. Now, you have interacted with Maxwell in
13 England many times, true?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. I want you to understand that the next
19 series of questions we'll be dealing just with your
20 actions in England, not with any of your actions in
21 the United States.
22 Will you understand that with regard to my
23 next questions?
24 A. Yes.
25 Q. While you were in England, you directed¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. You had Maxwell provide cameras to underage
6 girls, true?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. Your purpose in having Maxwell provide
12 cameras to underage girls was to have them take
13 sexually explicit pictures of themselves, true?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Have you ever seen Maxwell take a sexually
19 explicit picture of an underage girl?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. You and Maxwell viewed together sexually
25 explicit pictures of girls under the age of 18, true?¶
1 J. Epstein - Confidential
2 Maxwell to bring English females under the age of 18
3 to you for sexual purposes, true?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. While in England, in Miss Maxwell's private
9 residence, you observed Maxwell in the presence of
10 English females under the age of 18, true?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. While in England, Ms. Maxwell brought you
16 English females to satisfy your sexual purposes,
17 true?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. How young were the English girls that
23 Maxwell brought to you?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. Please describe how many times you have
5 seen Maxwell in private locations with girls under
6 the age of 18 in England.
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. You recognize the name Alexandra Dickson,
12 don't you, sir?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. Alexandra Dickson was an English girl
18 recruited by Maxwell for your sexual purposes, true?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Tell me how you came to meet Alexandra
24 Dickson in England.
25 A. Fifth.¶
1 J. Epstein - Confidential
2 Q. When you met Alexandra Dickson, she was
3 under the age of 18, true?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. How old was Alexandra Dickson when you
9 first met her?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. Based on your understanding of English
15 criminal law, you have observed Maxwell commit
16 English criminal offenses of a sexual nature in
17 England, true?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. Have you ever observed Maxwell commit a
23 crime in England?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. Please describe for me all the crimes you
5 have seen Maxwell commit in England.
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. While in England, you instructed Maxwell to
11 go to public places to solicit English girls to have
12 sex with you in England in exchange for compensation,
13 true?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. What instructions did you give to Maxwell
19 in England about what she should do for you?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. Please describe Maxwell's interactions in
25 England with females under the age of 18.¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. Please describe Maxwell's interactions in
7 England with e-mails under the age of 18 with whom
8 you had sex.
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. You have yourself solicited in public
14 places English girls under the age of 18 to have sex
15 with you in exchange for compensation, true?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. And just so I'm clear, you have, in
21 England, yourself, solicited in public places English
22 girls under the age of 18 to have sex with you in
23 exchange for compensation, true?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. Please describe your interaction with
5 females under the age of 18 in England.
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Please describe your interactions with
11 females under the age of 18 with whom you have had
12 sex in England.
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. You have had sex with females under the age
18 of 18 in England in exchange for compensation, true?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Based on your understanding of English
24 criminal law, you have committed domestic English sex
25 offenses in England, true?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. Without going into any acts you have com-
7 -- may have committed, what is your understanding of
8 English criminal law regarding soliciting sex?
9 MR. PAGLIUCA: Object to foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. During the time period 2000 to 2002,
13 Maxwell and you lived together for significant parts
14 of those years, true?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. During the time period 2000 to 2002,
20 Maxwell was responsible for much of the day-to-day
21 operation of your Florida mansion, true?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Who is the person you interacted with most
4 in the year 2000?
5 A. Fifth.
6 Q. Who was the person you interacted most in
7 the year -- let me rephrase.
8 Who is the person that you interacted with
9 the most in 2001?
10 A. Fifth.
11 Q. Who is the person that you interacted the
12 most with in 2002?
13 A. Fifth.
14 Q. Isn't it true, sir, that the person you
15 interacted with most in the year 2000 was Maxwell?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. Isn't it true the person you interacted
21 with most in the year 2001 was Maxwell?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Who did you interact the most with in the
4 year 2005?
5 A. Fifth.
6 Q. Isn't it true, sir, that you interacted the
7 most with Maxwell in the year 2005?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. Who was responsible for the day-to-day
13 operation of your Florida mansion in 2000 to 2002?
14 MR. PAGLIUCA: Object to form and
15 foundation. Asked and answered.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Isn't it true Maxwell was responsible for
19 much of the day-to-day operation of your Florida
20 mansion in 2000 to 2002?
21 MR. PAGLIUCA: Object to form and
22 foundation. Asked and answered.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. During the time period 2000 to 2002, you¶
1 J. Epstein - Confidential
2 were sexually -- sexually intimate with Maxwell,
3 true?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. You have remained on friendly terms with
9 Maxwell even through today, true?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. How would you describe your relationship
15 today with Maxwell?
16 A. Fifth.
17 Q. In the period 2000 to 2002, you directed
18 Maxwell to recruit girls under the age of 18 for you
19 to use for sexual purposes, true?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. How did you get the girls that you sexually
25 abused in 2001 to 2002?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. The directions you gave Maxwell for
7 recruiting girls for you was something to the effect
8 of the younger the better, true?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. Have you ever used the phrase "The younger
14 the better" in the presence of Maxwell?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. It's true, sir, that you've used the phrase
20 "The younger the better" in the presence of Maxwell,
21 right?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. You instructed Maxwell, then -- when she
4 was recruiting girls for you, she could bring you
5 girls of any race except for African Americans, true?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Have you ever discussed the age of underage
11 -- I'm sorry.
12 Have you ever discussed the race of
13 underage girls with Maxwell?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Why is it that you instructed Maxwell not
19 to bring you African American girls?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. I'm now going to ask you a question --
25 series of questions about overseas locations, and I¶
Page 153¶
1 J. Epstein - Confidential
2 want you to understand that each of these questions
3 is asking solely about your activities in these
4 overseas locations, and it's not in any way asking
5 for any information about actions that you may or may
6 not have committed in the United States.
7 Will you understand that with regard to
8 these next questions?
9 A. Yes.
10 Q. You have an apartment in Paris, France,
11 true?
12 A. Fifth.
13 Q. Maxwell has frequently been to your
14 apartment in Paris, France, true?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. Please list all the places in the world
20 where you have an apartment.
21 A. Fifth.
22 Q. While Maxwell has been at your apartment in
23 Paris, France, you have had numerous girls under the
24 age of 18 in your presence, true?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. While she was with you in Paris, Maxwell
6 recruited [REDACTED] girls under the age of 18 for to you
7 sex with, true?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. Please describe all of your interactions
13 with underage girls -- I'm sorry.
14 Please describe all of your interactions
15 with girls under the age of 18 in France.
16 A. Fifth.
17 Q. My next series of questions, again, are
18 only asking for your activities in the foreign
19 country in question, and that will be Thailand.
20 Will you understand that with regard to my
21 next questions?
22 A. Yes.
23 Q. You have been to Thailand, true?
24 A. Fifth.
25 Q. Have you ever been to Thailand?¶
1 J. Epstein - Confidential
2 A. Fifth.
3 Q. When you went to Thailand, Maxwell
4 accompanied you, true?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. When you went to Thailand, who went with
10 you?
11 A. Fifth.
12 Q. You saw Maxwell in the presence of Thai
13 females under the age of 18 in Thailand, true?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Describe what you did with Maxwell in
19 Thailand.
20 MR. PAGLIUCA: Object to foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. While in Thailand, you directed Maxwell to
24 recruit Thai females under the age of 18 for your
25 sexual purposes solely in Thailand, true?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. While in Thailand, Maxwell brought you
7 females under the age of 18, true?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. Without going into any acts that you may or
13 may not have committed, what is your understanding of
14 Thai criminal law regarding sex with girls under the
15 age of 18?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. Have you ever had sex with a Thai female
21 under the age of 18 in Thailand?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Have you ever had sex with anyone in
4 Thailand?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. Please describe all the sexual activities
10 you had in Thailand.
11 A. Fifth.
12 Q. My next series of questions are with regard
13 to the country of Brunei, and I want you to
14 understand that these questions deal solely with your
15 activities in Brunei. All right?
16 A. Yes.
17 Q. In 2002, you flew to Brunei with Maxwell on
18 your private jet, true?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Have you ever been to Brunei?
24 A. Fifth.
25 Q. Have you ever been to Brunei with Maxwell?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. You have had sex with girls from Brunei
7 under the age of 18 in Brunei?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. Please describe all the sex that you've
13 that in Brunei.
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Maxwell helped you find girls from Brunei
19 for you to have sex with in Brunei, true?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. What did Maxwell do in Brunei with you?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. Are you aware of inter- -- interaction by
6 Maxwell with women in Brunei?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. Are you aware of any interaction by Maxwell
12 with girls under the age of 18 in Brunei?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. Please describe all the interactions you
18 saw between Maxwell and girls from Brunei in Brunei.
19 A. Fifth.
20 Q. My next questions deal solely with your
21 activities in the Czech Republic.
22 Have you ever been to the Czech Republic?
23 A. Fifth.
24 Q. Have you ever been to the Czech Republic
25 with Maxwell?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. Please tell me about your sexual abuse in
7 the Czech Republic of Czech's -- Czech girls under
8 the age of 18.
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. Have you ever had sex in the Czech
14 Republic?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. Please tell me who you've had sex with in
20 the Czech Republic.
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. Please tell me about Maxwell's involvement¶
1 J. Epstein - Confidential
2 in your sexual abuse of Czech girls in the Czech
3 Republic.
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. Maxwell has been to the Czech Republic with
9 you?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. When you went to the Czech Republic, who
15 did you meet?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. Was Maxwell ever with you when you were in
21 the presence of girls under the age of 18 in the
22 Czech Republic?
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. It's true, sir, that Maxwell was with you
4 when you were in the presence of girls under the age
5 of 18 in the Czech Republic, right?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Please name all of the countries, not
11 including the United States, where you have seen
12 Maxwell in the presence of females who lived in those
13 countries under the age of 18.
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Please describe for me Maxwell's sexual
19 interactions with females under the age of 18 in
20 foreign countries with citizens of those countries.
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. Has Maxwell ever interacted with females¶
1 J. Epstein - Confidential
2 under the age of 18 in foreign countries?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. Has Maxwell ever interacted with minor
8 girls from the former country known as
9 Czechoslovakia?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. Based on your understanding of the criminal
15 laws of other foreign countries, have you ever
16 committed a crime of a sexual nature in another
17 foreign country?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. Please describe all the crimes of a sexual
23 nature that you have committed in foreign countries.
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. Based on your understanding of the criminal
5 laws of other countries, has Maxwell ever committed a
6 crime of a sexual nature in another country?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. Please describe all the crimes of a sexual
12 nature that you understand Maxwell has committed
13 foreign countries.
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. You are a multimillionaire, true, sir?
19 A. Fifth.
20 Q. How much are you worth today?
21 A. Fifth.
22 Q. It would not be financially burdensome for
23 you to hire someone to help collect any documents
24 that might be needed in this case, would it?
25 A. Fifth.¶
1 J. Epstein - Confidential
2 Q. You have millions and millions of dollars
3 available to your disposal to satisfy any need for
4 assistance in responding to discovery in this case,
5 true?
6 A. Fifth.
7 Q. You have legions -- well, let me strike
8 that.
9 How many lawyers do you have working on
10 this case for you?
11 A. Fifth.
12 Q. It's true that you have multiple lawyers
13 assisting you on this case, true?
14 A. Fifth.
15 Q. How much are you paying your lawyers to
16 assist you on this case?
17 A. Fifth.
18 MR. GOLDBERGER: And attorney-client
19 privilege.
20 BY MR. CASSELL:
21 Q. You and Maxwell became what could be
22 reasonably described as boyfriend and girlfriend in
23 about the mid 1990s, true?
24 MR. PAGLIUCA: Object to form and
25 foundation. Asked and answered.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. Since you became boyfriend and girlfriend,
5 you have given Maxwell significant amount --
6 significant amounts of money, true?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth. Let's take a
10 break.
11 VIDEO TECHNICIAN: Off the record at
12 10:34.
13 (A recess was taken.)
14 VIDEO TECHNICIAN: On the record at
15 10:44.
16 BY MR. CASSELL:
17 Q. How much money have you given Maxwell since
18 1996?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Since 1996, you have given Maxwell
24 significants -- significant amounts of money, true?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. For long periods of time since 1996, you
6 have paid Maxwell's living expenses, true?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. What do you know about the payment of
12 Maxwell's living expenses since 1996?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. Please describe all the gifts you provided
18 for Maxwell.
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Since 1996, you have purchased expensive
24 gifts for Maxwell, true?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. Please describe any funding you provided
6 for Maxwell's charities.
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. Since 1996, you've provided significant
12 funding for Maxwell's charities, true?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. Have you ever given Maxwell access to any
18 of your credit cards or bank accounts?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Since 1996, you've given Maxwell access to
24 some of your credit card and bank accounts, true?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. How did Maxwell buy her town home in
6 New York?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. You bought Maxwell a town home in New York,
12 true?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. What reason were you -- what reason did you
18 have for giving Maxwell gifts?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. One of the reasons you gave Maxwell gifts
24 was so -- so that she would continue recruiting girls¶
1 J. Epstein - Confidential
2 for you for sex, true?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. Directly or indirectly, you gave Maxwell
8 money to hire a paid image consultant named [REDACTED] Gow,
9 true?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. What do you know about an image consultant
15 in England named [REDACTED] Gow?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. You gave Maxwell money to hire a lawyer
21 named Phil Bard in England, true?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25 BY MR. CASSELL:¶
1 J. Epstein - Confidential
2 Q. Please tell me everything you know about a
3 lawyer named Phil Bard in England.
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. Have you ever transferred a significant
9 amount of money to Maxwell in the last several years?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. Within the last several years, you
15 transferred $500,000 to Maxwell, true?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. Tell me what you know about who is paying
21 for Maxwell's attorneys now.
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Directly or indirectly you're paying for
4 Maxwell's attorneys now, true?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. Since January 1st, 2015, what things of
10 value or money have you transferred to Maxwell?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. You have told various people that you own
16 the Palm Beach Police Department, true?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. In the period 1999 to 2005, what kind of
22 donations did you make to the Palm Beach Police
23 Department or to any organization associated with the
24 Palm Beach Police Department?
25 A. Fifth.¶
1 J. Epstein - Confidential
2 Q. Have you ever made donations to any
3 organizations associated with the Palm Beach Police
4 Department?
5 A. Fifth.
6 Q. Have you ever used money to influence the
7 testimony of a witness in a legal proceeding?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 (Plaintiff's Exhibit JE4, E-mail that
12 Jeffrey Epstein sent to Maxwell on January 12th, 2015
13 was marked for identification.)
14 BY MR. CASSELL:
15 Q. Let me show you what's been marked as JE4,
16 I think, we're up to, and copies for opposing
17 counsel.
18 Do you have that document in front of you,
19 sir?
20 A. Yes.
21 Q. Do you recognize this document?
22 A. Fifth.
23 Q. This is, in fact, an e-mail that you sent
24 to Maxwell on January 12th, 2015, true?
25 A. Fifth.¶
1 J. Epstein - Confidential
2 Q. What is this document?
3 A. Fifth.
4 Q. The first few words in this e-mail are,
5 "You can issue a reward to any of Virginia's
6 friends" -- and it appears to be acquaintances,
7 although there's a spelling issue.
8 Do you see that -- those first few words?
9 A. Yes.
10 Q. When you referred to "a reward" in this
11 e-mail, you were referring to cash payments, true?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. What did you mean by the term "reward" in
17 this e-mail?
18 A. Fifth.
19 Q. In the e-mail you said that "The strongest
20 is the Clinton dinner."
21 Do you see that reference in this e-mail?
22 It's on the second line.
23 A. Yes.
24 Q. What did you mean by the term "strongest"
25 in this?¶
1 J. Epstein - Confidential
2 MR. GOLDBERGER: Let me go back and
3 clarify.
4 The question was, do -- do you -- not
5 that he said it, but do you see this?
6 MR. CASSELL: That's right. No, I'm
7 not trying to pull a fast one here. Yeah.
8 MR. GOLDBERGER: Okay.
9 MR. CASSELL: I just want to circle in on
10 that word "strongest." And now I want to
11 ask you a question that does call for his
12 knowledge.
13 BY MR. CASSELL:
14 Q. What did you mean by the term "strongest"
15 in this e-mail?
16 A. Fifth.
17 Q. Isn't it true, sir, that by the term
18 "strongest," you meant that you had taken steps to
19 conceal the presence of Bill Clinton on your island?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. Isn't it true, sir, that part of what you
25 meant by the term "strongest" is that you knew it¶
1 J. Epstein - Confidential
2 would be difficult for Virginia to find support for
3 her testimony?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. Please describe all dinners you've ever had
9 with Bill Clinton.
10 A. Fifth.
11 Q. Please describe all dinners you and Maxwell
12 have ever had with Bill Clinton.
13 A. Fifth.
14 Q. Please describe all dinners you, Maxwell,
15 and Virginia have had together with Bill Clinton.
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. You have helped Maxwell feed information to
21 the media to try to undercut Virginia's credibility,
22 true?
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Please describe all steps you've taken to
4 assist Maxwell in getting information to the media
5 about the circumstances surrounding this case.
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. You helped Maxwell obtain information about
11 a Florida police report that Virginia made of a rape,
12 true?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. How did you obtain a copy of a police
18 report involving sexual assault on a minor,
19 specifically Virginia?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. It's true, sir, that you did obtain a copy
25 of a police report involving a sexual assault on¶
1 J. Epstein - Confidential
2 Virginia, true?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. Have you ever helped Maxwell leak any
8 reports to the media?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. You helped Maxwell leak a report about a
14 sexual assault committed against Virginia when she
15 was a minor to the media, true?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. You have been evading service of process
21 the last few months, true, sir?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. If we wanted to serve you with legal
4 process in the future, what would be the simplest way
5 to do that?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Are you willing to have your attorney
11 accept service of process on your behalf for future
12 proceedings in this case?
13 A. Fifth.
14 Q. If Miss [REDACTED] required your testimony at
15 trial in this case, would you be willing to appear
16 voluntarily?
17 A. Fifth.
18 Q. If you are not willing to appear
19 voluntarily at the upcoming trial, how can we serve
20 you with process to appear?
21 A. Fifth.
22 Q. When was the last time you traveled
23 overseas?
24 A. Fifth.
25 Q. Please describe all your overseas travel in¶
1 J. Epstein - Confidential
2 the last two years.
3 A. Fifth.
4 Q. How do you travel overseas?
5 A. Fifth.
6 Do you want this?
7 (Plaintiff's Composite Exhibit JE5, E-mail
8 Jeffrey Epstein received from Ms. Maxwell on about
9 July 18th, 2009 was marked for identification.)
10 BY MR. CASSELL:
11 Q. Thanks. Thank you.
12 I'm going to direct your attention now to
13 an exhibit, which I'll mark JE5. It's a composite
14 exhibit. I'm just looking at the first page of this
15 composite exhibit right now.
16 Do you see JE5, also known as Maxwell 14,
17 in front of you, sir?
18 A. Yes.
19 Q. This is an e-mail you received from
20 Ms. Maxwell on about July 18th, 2009, true?
21 A. Fifth.
22 Q. There's an e-mail address [REDACTED]
23 Do you see that e-mail on this document?
24 A. Yes.
25 Q. You understand that to be an e-mail that¶
1 J. Epstein - Confidential
2 belonged to Ms. Maxwell, true?
3 A. Fifth.
4 Q. You see on this document an e-mail address
5 known as jeevacation@Gmail.com? Do you see that
6 notation?
7 A. Yes.
8 Q. That's your e-mail address, true?
9 A. Fifth.
10 Q. Ms. Maxwell wrote to you, "How old was
11 Virginia in 1998 when she claims she started working
12 for you?"
13 Isn't that true?
14 A. I'm sorry. What's the question?
15 MR. PAGLIUCA: Did you see that or --
16 THE WITNESS: Do I see that or which --
17 I see it.
18 BY MR. CASSELL:
19 Q. Yeah. You see it.
20 Isn't that true that's a sentence that
21 Ms. Maxwell wrote to you, at least that's your
22 understanding?
23 A. Fifth.
24 Q. When you received that e-mail from
25 Ms. Maxwell, it's your understanding that Ms. Maxwell¶
1 J. Epstein - Confidential
2 was using the term "Virginia" to refer to [REDACTED]
3 [REDACTED], right?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. You see the term "Virginia" on this
9 document?
10 A. Yes.
11 Q. Who do you understand that term to refer
12 to?
13 A. Fifth.
14 Q. Who do you understand this e-mail to have
15 come from?
16 A. Fifth.
17 Q. Who do you understand received this e-mail?
18 A. Fifth.
19 Q. You and Ms. Maxwell were working together
20 to try defend the civil lawsuit that Virginia had
21 filed against you, true?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Sorry. Say it gain.
25¶
1 J. Epstein - Confidential
2 attorney-client privilege to the extent
3 Mr. Epstein's knowledge of the lawsuit or
4 the date of the lawsuit emanates from the
5 attorney-client communication.
6 MR. GOLDBERGER: Did you not get that?
7 THE COURT REPORTER: No.
8 MR. GOLDBERGER: I'll -- I'll rephrase
9 it.
10 In addition to the Fifth Amendment
11 privilege, we are invoking attorney-client
12 privilege to the extent that any knowledge
13 that Mr. Epstein has about a lawsuit filed
14 against him by someone by the name of
15 [REDACTED] came to him from attorneys.
16 BY MR. CASSELL:
17 Q. Did you respond to this e-mail, sir?
18 A. Fifth.
19 Q. It's true, sir, that you responded to this
20 e-mail, right?
21 A. Fifth.
22 Q. And your response was along the lines of
23 coordinating with Maxwell as to how best to defend
24 the lawsuit against you?
25 MR. PAGLIUCA: Object to form and¶
Page 183¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. You and Miss Maxwell were working together
4 to try to defend the civil lawsuit that Virginia
5 filed against you at this time, true?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 MR. GOLDBERGER: Against Mr. Epstein,
9 not against Ms. Maxwell?
10 MR. CASSELL: Correct.
11 MR. GOLDBERGER: Thank you.
12 THE WITNESS: Sorry. Okay.
13 MR. CASSELL: Let me just ask --
14 MR. GOLDBERGER: Okay.
15 BY MR. CASSELL:
16 Q. It's true, sir, that in July of 2009,
17 Virginia had a lawsuit pending against you, right?
18 A. Fifth.
19 MR. CASSELL: And you're taking the
20 Fifth with regard to a publicly-filed
21 lawsuit, I understand it; is that right?
22 MR. GOLDBERGER: That's correct.
23 BY MR. CASSELL:
24 Q. Did you respond to this e-mail?
25 MR. WEINBERG: I will also assert the¶
Page 185¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 (Plaintiff's Exhibit JE6, E-mail string
5 between Jeffrey Epstein and Ms. Maxwell on
6 about March 25th, 2011 was marked for
7 identification.)
8 BY MR. CASSELL:
9 Q. All right. Let's go to another document,
10 which I'll mark as JE6.
11 Do you see JE6 in front of you?
12 A. Yes.
13 Q. This is an e-mail string between you and
14 Ms. Maxwell on about March 25th, 2011, right?
15 MR. GOLDBERGER: There appears to be
16 one e-mail only.
17 Do you have the right exhibit?
18 MR. CASSELL: [REDACTED], I'm sorry. No -- are
19 we looking at the same thing? I see one
20 e-mail and then a second one.
21 MR. GOLDBERGER: I'm sorry.
22 BY MR. CASSELL:
23 Q. This appears to be a -- an e-mail from
24 Maxwell to you, followed by an e-mail from you to
25 Maxwell, correct?¶
1 J. Epstein - Confidential 2 A. Fifth. 3 Q. This is an c-mail -- well, let me see. 4 Maxwell sent you an e-mail to the effect of 5 "Any news on V work story? Am I right not allowed 6 full-time employment at I5?" 7 That's what she sent to you, right? 8 A. I'm sorry. Do you -- is that -- are you 9 asking me that's what it says on this document? 10 Q. No. I'm asking you, was it your 11 understanding that Maxwell was sending you that 12 question, right? 13 A. Fifth. 14 Q. And you responded by saying, "Are you 15 getting what you need?" 16 MR. PAGLIUCA: Object to form and 17 foundation. 18 THE WITNESS: I'm sorry. Are you 19 asking me if that's what it says? 20 BY MR. CASSELL: 21 Q. No. I'm asking, is that what you 22 responded? 23 A. Fifth. 24 Q. It's true, sir, that you responded to an 25 e-mail from Maxwell on about March 25th, 2011, right?¶
1 J. Epstein - Confidential 2 A. Fifth. 3 Q. What did you say in response to Maxwell's 4 question? 5 A. Fifth. 6 MR. CASSELL: Just so the record is 7 clear, this is also identified as 8 confidential GM-00649. Hang on one second. 9 BY MR. CASSELL: 10 Q. By the phrase "V work story," you 11 understood Ms. Maxwell to be referring to Virginia's 12 age at the time Maxwell first met Virginia, true? 13 MR. PAGLIUCA: Object to form and 14 foundation. 15 THE WITNESS: Fifth. 16 BY MR. CASSELL: 17 Q. What did you understand the phrase "V work 18 story" to mean? 19 MR. PAGLIUCA: Object to form and 20 foundation. 21 THE WITNESS: Fifth. 22 BY MR. CASSELL: 23 Q. And by the phrase "getting what you need," 24 you meant getting materials to try to cover up your 25 sexual abuse of Virginia, right?¶
1 J. Epstein - Confidential 2 MR. PAGLIUCA: Object to form and 3 foundation. 4 THE WITNESS: Fifth. 5 BY MR. CASSELL: 6 Q. In this e-mail and other communications, 7 you and Maxwell were trying to cover up sexual abuse 8 of Virginia, right? 9 MR. PAGLIUCA: Object to form and 10 foundation. 11 THE WITNESS: Fifth. 12 BY MR. CASSELL: 13 Q. By the phrase "getting what you need." what 14 did you mean? 15 A. Fifth. 16 Q. All right. One more -- 17 A. Here you go. 18 Q. did you instruct Maxwell to delete any 19 e-mails at the time? 20 MR. PAGLIUCA: Object to form and 21 foundation. 22 THE WITNESS: Fifth. 23 BY MR. CASSELL: 24 Q. Did you instruct Maxwell to delete her 25 e-mails in 2015?¶
1 J. Epstein - Confidential 2 MR. PAGLIUCA: Object to form and 3 foundation. 4 THE WITNESS: Fifth. 5 (Plaintiffs Exhibit JE7, Transcription of 6 a string of e-mails between Jeffrey Epstein and Ms. 7 Maxwell in about May of 2011 was marked for 8 identification.) 9 BY MR. CASSELL: 10 Q. Mark this as JE6 -- 11 MR. PAGLIUCA: Seven. 12 MR. CASSELL: seven? Thank you. 13 Thanks, Jeff. 14 THE WITNESS: Thank you. 15 BY MR. CASSELL: 16 Q. Do you have JE7 in front of you? 17 A. Yes. 18 Q. This is. in fact, an accurate transcription 19 of a string of e-mails between you and Ms. Maxwell in 20 about May of 2011? 21 MR. PAGLIUCA: Object to form and 22 foundation. 23 THE WITNESS: Fifth. 24 BY MR. CASSELL: 25 Q. What is this document?¶
1 J. Epstein - Confidential 2 A. Fifth. 3 Q. As reflected in this document, you sent an 4 e-mail on May 3rd. 2011. to Maxwell that read. "Where 5 are you? The pictures of you look good. Don't 6 fret."¶
7 That's what you sent to her, right? 8 A. Again, you're asking me, is that what it 9 says on the paper?¶
10 Q. No. I'm asking a substantive question.¶
11 Is this what you sent to her?¶
12 A. Fifth.¶
13 Q. You sent that e-mail to her, didn't you?¶
14 A. Fifth.¶
15 Q. Who sent that e-mail to her?¶
16 A. Fifth.¶
17 Q. When you wrote -- wrote the words, "Don't 18 fret," you meant that you were taking steps to avoid 19 further distribution to press stories about your¶
20 sexual abuse of Virginia, right?¶
21 MR. PAGLIUCA: Object to form and 22 foundation.¶
23 THE WITNESS: Fifth.¶
24 BY MR. CASSELL:¶
25 Q. What did you mean by the words "Don't fret"¶
1 J. Epstein - Confidential¶
2 in the e-mail?¶
3 A. Fifth.¶
4 We done?¶
5 Q. Yeah.¶
6 (Plaintiffs Exhibit JE8, E-mail that¶
7 Jeffrey Epstein sent to Maxwell on January 15th, 2015¶
8 was marked for identification.)¶
9 BY MR. CASSELL:¶
10 Q. I'm going to mark an exhibit here as JE8.¶
11 Do you have JE8 in front of you?¶
12 A. Yes.¶
13 MR. CASSELL: It's also Maxwell 18 and¶
14 also GM001081, for the record.¶
15 BY MR. CASSELL:¶
16 Q. This is an e-mail that you sent to Maxwell 17 on January 15th, 2015, isn't it?¶
18 A. Fifth.¶
19 Q. Who sent this e-mail on January 15. 2015?¶
20 A. Fifth.¶
21 Q. This e-mail says, do you want¶
22 to come out and say she was the girlfriend, during 23 the time period?¶
24 Do you see that there?¶
25 A. Yes.¶
1 J. Epstein - Confidential¶
2 Q. What did you mean when you wrote those 3 words?¶
4 A. Fifth.¶
5 Q. In fact, sir, those words mean that you 6 wanted a person named -- strike that.¶
7 In fact, what that e-mail means is that you 8 were offering to Maxwell that a woman named 9 would pretend to be your girlfriend during the time. 10 right?¶
11 MR. PAGLIUCA: Object to form and 12 foundation.¶
13 THE WITNESS: Fifth.¶
14 BY MR. CASSELL:¶
15 Q. The reason you and Maxwell were 16 communicating at this time was to try to work 17 together to attack Virginia's credibility, true?¶
18 MR. PAGLIUCA: Object to form and 19 foundation.¶
20 THE WITNESS: Fifth.¶
21 BY MR. CASSELL:¶
22 Q. Why were you and Maxwell communicating at 23 this time?¶
24 A. Fifth.¶
25 Q. You and Maxwell were communicating to try¶
1 J. Epstein - Confidential¶
2 3 an invent a story to conceal the fact that the two of you had sexually abused Virginia, right?¶
4 5 MR. PAGLIUCA: Object to form and foundation.¶
6 THE WITNESS: Fifth.¶
7 BY MR. CASSELL:¶
8 9 Q. When you used the phrase "to come out and say," what did you mean?¶
10 A. Fifth.¶
11 12 13 Q. In fact, you were trying to get someone to come out to falsely claim to be your girlfriend at that time, right?¶
14 15 MR. PAGLIUCA: Object to form and foundation.¶
16 THE WITNESS: Fifth.¶
17 BY MR. CASSELL:¶
18 19 20 21 Q. And the reason you needed someone to say that they were your girlfriend at the time was to cover up the fact that Maxwell was your girlfriend at the time, right?¶
22 23 MR. PAGLIUCA: Object to form and foundation.¶
24 THE WITNESS: Fifth.¶
25¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. With regard to the time period referred to
4 in this e-mail, who was your girlfriend?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. In fact, during the time when Virginia was
10 with you, Maxwell was your girlfriend, right?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. Who was your girlfriend when Virginia was
16 with you?
17 MR. PAGLIUCA: Object to form.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. Did Maxwell respond to this e-mail?
21 A. Fifth.
22 Q. In fact, Maxwell did respond to this
23 e-mail, true?
24 A. Fifth.
25 Q. You and Maxwell decided together that¶
1 J. Epstein - Confidential
2 pseudonym Jane Doe 102, filed a public lawsuit
3 against you for sexual abuse, right?
4 A. Fifth and attorney-client.
5 MR. GOLDBERGER: I'll assert the
6 attorney-client privilege for you.
7 BY MR. CASSELL:
8 Q. It's a matter of public record that you
9 later settled that lawsuit, right?
10 A. Fifth.
11 MR. GOLDBERGER: And attorney-client
12 privilege. And confidentiality of any
13 agreement that may have existed.
14 BY MR. CASSELL:
15 Q. How much money, if any, did you pay to
16 settle that lawsuit?
17 A. Fifth.
18 MR. GOLDBERGER: Attorney-client
19 privilege and confidentiality of any
20 agreement that may or may not have existed.
21 BY MR. CASSELL:
22 Q. That lawsuit involved two parties, you and
23 [REDACTED], right?
24 A. Fifth.
25 Q. It is you who is insisting on¶
Page 195¶
1 J. Epstein - Confidential
2 trying to pass off [REDACTED] as your girlfriend who be
3 too easily exposed as a lie, right?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. Please describe the plan that you and
9 Maxwell came up with to respond to Virginia's
10 allegations that she had been sexually abused by the
11 two of you.
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. In fact, you two came up with a plan to try
17 to attack Virginia's credibility, right?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. Now, if we go to 2009 -- we're done with
23 that document.
24 A. Okay.
25 Q. In 2009, [REDACTED], proceeding under the¶
Page 197¶
1 J. Epstein - Confidential
2 confidentiality of the settlement of that lawsuit,
3 right?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 MR. GOLDBERGER: Attorney-client
8 privilege.
9 BY MR. CASSELL:
10 Q. If Virginia were to provide to Maxwell the
11 confidential settlement agreement, that would be, to
12 your personal understanding, a violation of the terms
13 of the settlement agreement?
14 A. Fifth.
15 MR. GOLDBERGER: And attorney-client
16 privilege.
17 BY MR. CASSELL:
18 Q. You could sue Virginia if she gave Maxwell
19 the confidential settlement agreement, right?
20 A. Fifth.
21 MR. GOLDBERGER: Attorney-client
22 privilege.
23 Do you want to give me a standing
24 objection to attorney-client privilege on --
25 on any of the questions concerning the¶
1 J. Epstein - Confidential
2 settlement agreement?
3 MR. CASSELL: Yes.
4 MR. GOLDBERGER: Okay.
5 MR. WEINBERG: And a standing -- and a
6 standing objection to these questions are
7 based, if there is a confidentiality
8 agreement, on the agreement, which is
9 subject to confidentiality.
10 MR. PAGLIUCA: Which I have asked for
11 and don't have.
12 MR. CASSELL: Right. Which is why --
13 well, in any event.
14 BY MR. CASSELL:
15 Q. Sir, you are willing to sign an
16 unconditional waiver allowing Virginia to turn over
17 the settlement agreement to Maxwell, right?
18 A. Fifth.
19 Q. Now, if we talk about the 2009 litigation
20 between you and Maxwell, during that litigation you
21 conveyed threats to Virginia?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25¶
1 J. Epstein - Confidential
2 A. Fifth.
3 Q. When did you first meet Alan Dershowitz?
4 A. Fifth.
5 Q. It would be fair to describe
6 Alan Dershowitz as a good friend of yours, true?
7 A. Fifth.
8 Q. Please describe your relationship with
9 Alan Dershowitz.
10 A. Fifth.
11 Q. Alan Dershowitz has sent drafts of books he
12 was writing for you to review, right?
13 A. Fifth.
14 Q. What books of Alan Dershowitz' have you
15 read?
16 A. Fifth.
17 Q. What drafts of Alan Dershowitz' have you
18 read?
19 A. Fifth.
20 Q. Dershowitz was your lawyer as well as your
21 friend, right?
22 A. Fifth.
23 Q. Without discussing any particular
24 attorney-client communications, what was the general
25 type of legal work he did for you?¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Indirectly you threatened Virginia with
4 harm if she did not agree to your proposed settlement
5 terms, true?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Without disclosing any amount that you
11 ultimately paid, if any, it was your intent that your
12 threats would reduce the amount that you would have
13 to pay to Virginia, right?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Please describe all the threats you've ever
19 made to Virginia.
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. Sir, you know Harvard Law Professor, now
25 former law professor, Alan Dershowitz?¶
1 J. Epstein - Confidential
2 A. Fifth.
3 MR. WEINBERG: Attorney-client
4 privilege.
5 MR. CASSELL: Attorney-client
6 privilege? █, okay.
7 BY MR. CASSELL:
8 Q. When did Dershowitz first become your
9 lawyer?
10 MR. WEINBERG: Attorney-client
11 privilege.
12 MR. CASSELL: The date is
13 attorney-client privilege?
14 MR. WEINBERG: Yes.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. It is true, sir, that Dershowitz first
18 became your lawyer in about 1999, right?
19 MR. WEINBERG: Attorney-client
20 privilege.
21 BY MR. CASSELL:
22 Q. Has Dershowitz ever provided business
23 advice for you?
24 A. Fifth.
25 Q. Has Dershowitz ever provided you business¶
1 J. Epstein - Confidential
2 advice of a nonlegal nature?
3 A. Fifth.
4 Q. Have you had any business relationships of
5 any kind with Dershowitz?
6 A. Fifth.
7 Q. It's true, sir, that you have had business
8 relationships with Dershowitz, right?
9 A. Fifth.
10 Q. In 1999, you had business relationships
11 with Dershowitz, true?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. When was the last time you spoke to
17 Alan Dershowitz?
18 A. Fifth.
19 Q. I want to focus your attention to the time
20 frame immediately after December 30th, 2014, when
21 Virginia's allegations were first made in a court
22 filing.
23 If we talk about that time frame, did you
24 discuss Virginia's allegations with Dershowitz?
25 MR. GOLDBERGER: You got it, Marty, or¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 MR. GOLDBERGER: Attorney-client
4 privilege to the extent I understand what
5 "agent" means.
6 BY MR. CASSELL:
7 Q. Did you authorize Dershowitz to make any
8 public statements on your behalf?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 MR. GOLDBERGER: Attorney-client
12 privilege.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. If Dershowitz made any public statements
16 about your views on Virginia, were those authorized?
17 MR. GOLDBERGER: Attorney-client
18 privilege?
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. Did you ever tell Dershowitz that you were
22 outraged by Virginia's statements?
23 A. Fifth.
24 MR. GOLDBERGER: Attorney-client
25 privilege.¶
1 J. Epstein - Confidential
2 I'll -- I'm on -- why don't I just do it,
3 because they're having a hard time hearing
4 you.
5 MR. WEINBERG: Okay.
6 MR. GOLDBERGER: Thank you. And
7 attorney-client privilege.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. You did discuss Virginia's allegations with
11 Dershowitz, didn't you?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 MR. GOLDBERGER: And attorney-client
16 privilege.
17 BY MR. CASSELL:
18 Q. Was he your lawyer at that time, sir?
19 A. Fifth.
20 MR. GOLDBERGER: Attorney-client
21 privilege.
22 BY MR. CASSELL:
23 Q. Was he your agent at that time?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. In fact, sir, you've never told Dershowitz
4 that you were outraged by Virginia's statements, did
5 you?
6 A. Fifth.
7 MR. GOLDBERGER: And attorney-client
8 privilege.
9 BY MR. CASSELL:
10 Q. The reason you never told Dershowitz that
11 is that you knew that Virginia's statements were
12 true, didn't you?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. When Alan Dershowitz said, "He's as
18 outraged as I am," referring to you, that was not a
19 true statement, was it?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 MR. GOLDBERGER: And attorney-client
24 privilege.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Was that an authorized statement on your
4 behalf by Alan Dershowitz?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 MR. GOLDBERGER: Attorney-client
9 privilege.
10 BY MR. CASSELL:
11 Q. In 2000 and 2001, Dershowitz came to visit
12 you at your Florida mansion in Palm Beach, true?
13 A. Fifth.
14 MR. GOLDBERGER: Attorney-client
15 privilege.
16 BY MR. CASSELL:
17 Q. In 2000 and 2001, Dershowitz came to visit
18 you in your New York mansion, true?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 MR. GOLDBERGER: Attorney-client
23 privilege.
24 BY MR. CASSELL:
25 Q. In 2001 and 2001, Dershowitz visited your¶
1 J. Epstein - Confidential
2 ranch named Zorro in the Greater Santa Fe, New Mexico
3 area several times, true?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 MR. GOLDBERGER: Attorney-client
8 privilege.
9 BY MR. CASSELL:
10 Q. In 2000 and 2001 Dershowitz visited your
11 island in the U.S. Virgin Islands as well, true?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 MR. GOLDBERGER: Attorney-client.
16 BY MR. CASSELL:
17 Q. If we focus in on the years 2000 and 2001,
18 how many times did Dershowitz visit you in your
19 various homes?
20 A. Fifth.
21 Q. Please describe all your interactions with
22 Dershowitz in 2000 and 2001.
23 A. Fifth.
24 MR. GOLDBERGER: Attorney-client
25 privilege.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Has Dershowitz ever walked into a room
4 where you and Virginia were interacting sexually?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. It's true, sir, that Dershowitz did walk
10 into a room and when you Virginia were interacting
11 sexually, right?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. Please describe the circumstances
17 surrounding Dershowitz walking into a room with you
18 and Virginia interacting sexually.
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Your sexual preference is for minor girls,
24 right?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation. Asked and answered.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. If we focus in on the period just 2005 to
6 2006, at that time, you were targeting minor girls
7 for sexual abuse, true?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. If we focus in just on the year 2005, in
13 that year you were targeting minor girls for sexual
14 abuse, right?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. Your sexual abuse came to the attention of
20 law enforcement authorities in 2005, right?
21 A. Fifth.
22 Q. And thereafter your defense attorneys
23 negotiated a non-prosecution agreement for you with
24 the U.S. Attorney's Office, true?
25 A. Fifth.¶
1 J. Epstein - Confidential
2 MR. GOLDBERGER: And attorney-client
3 privilege.
4 BY MR. CASSELL:
5 Q. One of the attorneys negotiating on your
6 behalf was Alan Dershowitz, true?
7 A. Fifth.
8 MR. GOLDBERGER: Attorney-client.
9 (Plaintiff's Exhibit JE9, Document 361-46
10 on the public record in the case Jane Doe versus
11 United States 908CD80736 in the Southern District of
12 Florida, a document signed by Gerald Lefcourt and
13 Alan Dershowitz was marked for identification.)
14 BY MR. CASSELL:
15 Q. I want to show you now an exhibit which
16 we'll mark as JE9, which I'll note, for the record,
17 is Document 361-46 on the public record in the case
18 Jane Doe versus United States 908CD80736 in the
19 Southern District of Florida.
20 This is a document signed by
21 Gerald Lefcourt and Alan Dershowitz, as you can see
22 on the last page.
23 A. I see the last page.
24 Q. All right. This was a statement sent on
25 your behalf to prosecutors in that -- in the criminal¶
1 J. Epstein - Confidential
2 investigation and case in the Southern District of
3 Florida, right?
4 A. I'm sorry. Say again.
5 Q. This is a document or a statement sent on
6 your behalf to prosecutors in the criminal
7 investigation and case in the Southern District of
8 Florida?
9 A. That's what it says.
10 Q. If Alan Dershowitz were to write in this
11 letter that "Epstein never targeted minors," that
12 would be a false statement, wouldn't it?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. In fact, you had told Alan Dershowitz that
18 you had targeted minors?
19 MR. WEINBERG: Attorney-client privilege.
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. And without regard to any communications
25 that you may or may not have had with Mr. Dershowitz,¶
1 J. Epstein - Confidential
2 Mr. Dershowitz had observed you having sexual
3 interactions with at least one minor --
4 MR. PAGLIUCA: Object to form --
5 BY MR. CASSELL:
6 Q. -- at the time you wrote this letter,
7 right?
8 MR. PAGLIUCA: I'm sorry. I don't know
9 if I spoke over you the last --
10 Did you get the question?
11 THE COURT REPORTER: No -- yes, but...
12 Objection --
13 MR. PAGLIUCA: Okay. Yeah.
14 Object to form and foundation.
15 THE COURT REPORTER: Thank you.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Two of the attorneys in the U.S. Attorney's
19 Office at that time were Matthew Menchel and
20 Andrew Lurie, true?
21 A. That's what it says on the document.
22 Q. And you also -- you knew that there were
23 two U.S. Attorneys in the office at that time by the
24 name of Matthew Menchel and Andrew Lurie, right?
25 A. Fifth.¶
1 J. Epstein - Confidential
2 MR. GOLDBERGER: And attorney-client
3 privilege.
4 MR. CASSELL: Attorney-privilege of
5 prosecutors?
6 MR. GOLDBERGER: Of what he knew.
7 MR. CASSELL: Okay. I got you.
8 BY MR. CASSELL:
9 Q. While you were negotiating with the U.S.
10 Attorney's Office, you were also working with Menchel
11 and Lurie to help them secure lucrative employment
12 when they left the office, right?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. What do you know about the current
18 employment of Matthew Menchel?
19 A. Fifth.
20 Q. What do you know about the current
21 employment of Andrew Lurie?
22 A. Fifth.
23 Q. Please describe all of the circumstances
24 you are aware of concerning Matthew Menchel's
25 departure from the U.S. Attorney's Office.¶
1 J. Epstein - Confidential
2 A. Fifth.
3 Q. Please describe all the circumstances you
4 are aware of involving the departure of Andrew Lurie
5 from the U.S. Attorney's Office.
6 A. Fifth.
7 Q. One person you sexually trafficked Virginia
8 to was then Harvard Law Professor Allan Dershowitz,
9 right?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. You arranged for Dershowitz to sexually
15 abuse Virginia in your Florida mansion, right?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. All right. You arranged for Dershowitz to
21 sexually abuse Virginia in your New York mansion,
22 right?
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. You arranged for Dershowitz to sexually
4 abuse Virginia at your New -- New Mexico ranch,
5 right?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. You arranged for Dershowitz to sexually
11 abuse Virginia Tryland (phonetic) in the U.S. Virgin
12 Islands, true?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. You arranged for Dershowitz to sexually
18 abuse Virginia on the jet airplane you own, right?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. By the way, without any regard to sexual
24 conduct that you may or may not have had on your jet,
25 is your jet equipped with a bed?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. Please describe the bed on your jet.
7 A. Fifth.
8 Q. Please describe every time Dershowitz was
9 inside your -- one of your homes in the presence of
10 girls under the age of 18.
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. Maxwell was well aware of Dershowitz's
16 sexual abuse of Virginia, right?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. Please describe all the interactions
22 between Dershowitz and Maxwell in your homes in the
23 time frame 2000 to 2001.
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. Please describe all the interactions
5 between Maxwell and Dershowitz in any of your homes
6 in the time frame 2004 to 2006.
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. You have sexually trafficked Virginia to a
12 number of your other friends, right?
13 MR. PAGLIUCA: Object to form and
14 foundation. Asked and answered.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
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1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. You and Maxwell sent Virginia to have sex
4 with [REDACTED] true?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. You and Maxwell sent Virginia to have sex
10 with Marvin Minsky, true?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. You and Maxwell sent Virginia to have sex
16 with [REDACTED], true?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. You and Maxwell sent Virginia to have sex
22 with [REDACTED], true?
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Please give me the names of the other men
4 you and Maxwell sent Virginia to have sex with.
5 MR. PAGLIUCA: Object to the form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. Isn't it true that in the time period 2000
10 to 2001, you were close friends with Bill Clinton?
11 A. Fifth.
12 Q. And even into 2002 you remained close
13 friends with Bill Clinton, right?
14 A. Fifth.
15 Q. Bill Clinton flew on your jet a number of
16 times in 2002, right?
17 A. Fifth.
18 Q. For example, in May of 2002, Bill Clinton
19 was on your jet several times, right?
20 A. Fifth.
21 Q. Bill Clinton visited your island in the
22 U.S. Virgin Islands in about 2002, true?
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. How did Bill Clinton get to your island
4 when he came to visit you?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. Sir, isn't it true, Bill Clinton got to the
10 island by having Maxwell fly him there on a
11 helicopter?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. Do you own a helicopter, sir?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. In fact, sir, you own a helicopter in the
22 U.S. Virgin Islands for purposes of flying guests to
23 your private island there, right?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. Please describe all the ways people can get
5 to your private island in the U.S. Virgin Islands.
6 MR. PAGLIUCA: Object to form.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. Maxwell frequently flew a helicopter in the
10 U.S. Virgin Islands, right?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. Maxwell was trained to fly your helicopter
16 in the U.S. Virgin Islands, right?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. Maxwell frequently flew a helicopter in the
22 U.S. Virgin Islands, right?
23 MR. PAGLIUCA: Object to form and
24 foundation. Asked and answered.
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential¶
2 BY MR. CASSELL:¶
3 Q. When Bill Clinton visited your private
4 island in the U.S. Virgin Islands, please describe
5 all the steps that you took to conceal his presence
6 there.¶
7 MR. PAGLIUCA: Object to form and
8 foundation.¶
9 THE WITNESS: Fifth.¶
10 BY MR. CASSELL:¶
11 Q. When Bill Clinton came to your private
12 island in the U.S. Virgin Islands, please describe
13 anyone who he was accompanied by.¶
14 MR. PAGLIUCA: Object to form and
15 foundation.¶
16 THE WITNESS: Fifth.¶
17 BY MR. CASSELL:¶
18 Q. When Bill Clinton came to your island, he
19 was accompanied by two young women who were
20 approximately 18 years old, true?¶
21 MR. PAGLIUCA: Object to form and
22 foundation.¶
23 THE WITNESS: Fifth.¶
24 BY MR. CASSELL:¶
25 Q. Please list every place you and¶
1 J. Epstein - Confidential¶
2 Bill Clinton have ever been together.¶
3 MR. PAGLIUCA: Object to form.¶
4 THE WITNESS: Fifth.¶
5 BY MR. CASSELL:¶
6 Q. Please list everyplace you, Maxwell, and
7 Bill Clinton have been together simultaneously.¶
8 MR. PAGLIUCA: Object to form and
9 foundation.¶
10 THE WITNESS: Fifth.¶
11 BY MR. CASSELL:¶
12 Q. On May 22nd, 2002, you and Maxwell flew
13 with Bill Clinton on your private jet, true?¶
14 MR. PAGLIUCA: Object to form and
15 foundation.¶
16 THE WITNESS: Fifth.¶
17 BY MR. CASSELL:¶
18 Q. On May 22nd, 2002 you and Maxwell and
19 Bill Clinton flew from the Atsugi Naval Air facility
20 in Japan to Khabarovsk, Russia, true?¶
21 MR. PAGLIUCA: Object to form and
22 foundation.¶
23 THE WITNESS: Fifth.¶
24 BY MR. CASSELL:¶
25 Q. On that same trip you, Maxwell, and¶
1 J. Epstein - Confidential¶
2 Bill Clinton flew to China, right?¶
3 MR. PAGLIUCA: Object to form and
4 foundation.¶
5 THE WITNESS: Fifth.¶
6 BY MR. CASSELL:¶
7 Q. And you also flew to Singapore, right?¶
8 MR. PAGLIUCA: Object to form and
9 foundation.¶
10 THE WITNESS: Fifth.¶
11 BY MR. CASSELL:¶
12 Q. And you also flew together to Bangkok?¶
13 MR. PAGLIUCA: Object to form and
14 foundation.¶
15 THE WITNESS: Fifth.¶
16 BY MR. CASSELL:¶
17 Q. Just so we're clear on that, in May
18 of 2002, you, Bill Clinton, and Defendant Maxwell all
19 flew to Bangkok together, right?¶
20 MR. PAGLIUCA: Object to form and
21 foundation.¶
22 THE WITNESS: Fifth.¶
23 BY MR. CASSELL:¶
24 Q. And later, on that same trip, you, Maxwell,
25 and Bill Clinton all flew to Brunei together, true?¶
1 J. Epstein - Confidential¶
2 MR. PAGLIUCA: Object to form and
3 foundation.¶
4 THE WITNESS: Fifth.¶
5 BY MR. CASSELL:¶
6 Q. You've heard of the Clinton Foundation,
7 right?¶
8 A. Fifth.¶
9 Q. Please describe all of your interactions
10 with the Clinton Foundation.¶
11 A. Fifth.¶
12 Q. Is it true you that you helped Bill Clinton
13 organize the Clinton Foundation?¶
14 A. Fifth.¶
15 Q. Did you discuss with Bill Clinton the idea
16 of creating a foundation?¶
17 A. Fifth.¶
18 (Plaintiff's Exhibit JE10, Subpoena in this
19 case for Jeffrey Epstein to appear at deposition was
20 marked for identification.)¶
21 MR. CASSELL: I'm going to hand you one
22 more -- here we are. This will become JE10 in
23 this case. And I represent this is the subpoena
24 in this case to appear for the deposition. I
25 only got one of those.¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: I can share. That's
3 fine.
4 BY MR. CASSELL:
5 Q. Have you seen this document before today,
6 sir?
7 A. Fifth.
8 Q. I want to direct your attention to page 8
9 of this document regarding -- you see page 8?
10 A. Yes, sir.
11 Q. And you see there's the heading "Documents
12 to Be Produced Pursuant to This Subpoena"?
13 A. Yes.
14 Q. Did you bring any documents with you today
15 pursuant to this subpoena?
16 A. Fifth.
17 MR. WEINBERG: Mr. Epstein would assert
18 the Fifth Amendment as well as the act of
19 production for the protections against
20 responding to that question or producing any
21 documents, relying on the Supreme Court
22 decision in Hubble, the Second Circuit's
23 August 1 decision in Greenfield.
24 MR. CASSELL: Understood. And I'll assume
25 you have a standing objection based on the¶
1 J. Epstein - Confidential
2 grounds that you just described to all my
3 questions with regard to this subpoena.
4 MR. GOLDBERGER: Just so we're clear,
5 the Fifth Amendment objection as to act of
6 production is going to apply to
7 everything that --
8 MR. CASSELL: Yeah. We disagree. But
9 I understand you have a Fifth Amendment and
10 act of production.
11 MR. GOLDBERGER: Yes.
12 MR. CASSELL: Let's just hang onto that
13 a second.
14 MR. GOLDBERGER: Sure.
15 BY MR. CASSELL:
16 Q. Sir, you've made no effort to collect any
17 of the documents requested here, right?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth Amendment.
21 BY MR. CASSELL:
22 Q. In the last three weeks, you've made no
23 search at all for the 22 categories of documents
24 requested here, right?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. Where are the documents covered by these 22
6 requested categories?
7 A. Fifth.
8 Q. You have not produced any privilege log for
9 these items, have you?
10 A. Fifth.
11 Q. It would not be burdensome for you to
12 search for any of these documents, would it?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. It would be quite simple for you to run
18 search terms, such as Virginia, through your e-mail
19 accounts, right?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. And you have plenty of money to fund any of
25 the searches that would be required to produce these¶
1 J. Epstein - Confidential
2 documents, right?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. I want to direct your attention to the
8 item 13, which requests all --
9 A. Sorry --
10 MR. GOLDBERGER: Page 9 of the -- of
11 the subpoena.
12 THE WITNESS: Okay.
13 BY MR. CASSELL:
14 Q. -- which request all telephone records
15 associated with you, including cell phone records,
16 from 1999 to present that shown communications with
17 Maxwell, Ghislaine Maxwell.
18 You've taken no steps to secure those
19 documents, right?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. You have, in fact, received electronic and
25 paper records from a cellular telephone provider¶
1 1 Epstein - Confidential 2 reflecting such calls on your cell phone, right? 3 MR. PAGLIUCA: Object to form and 4 foundation. 5 THE WITNESS: Fifth. 6 BY MR. CASSELL: 7 Q. And on those records over the last 8 20 months would be telephone calls between you and 9 Maxwell, right? 10 MR. PAGLIUCA: Object to form and 11 foundation. 12 THE WITNESS: Fifth. 13 BY MR. CASSELL: 14 Q. I'm going to direct your attention now to 15 item seven. 16 You have documents relating to 17 communications with Ghislaine Maxwell, true, sir? 18 MR. PAGLIUCA: Object to form and 19 foundation. 20 THE WITNESS: Fifth. 21 BY MR. CASSELL: 22 Q. You maintain various e-mail accounts, 23 right? 24 MR. PAGLIUCA: Object to form and 25 foundation.¶
1 J. Epstein - Confidential 2 MR. PAGLIUCA: Object to form and 3 foundation. 4 THE WITNESS: Fifth. 5 BY MR. CASSELL: 6 Q. Please describe all the communications 7 you've had with Maxwell about crimes she has 8 committed. 9 MR. PAGLIUCA: Object to form and 10 foundation. 11 THE WITNESS: Fifth. 12 BY MR. CASSELL: 13 Q. Ms. Maxwell has admitted to you that she 14 has sexually abused minors, right? 15 MR. PAGLIUCA: Object to form and 16 foundation. 17 THE WITNESS: Fifth. 18 BY MR. CASSELL: 19 Q. You know a Renaldo Rizzo, right? 20 A. Fifth. 21 Q. You know that Renaldo Rizzo is an estate 22 manager for Glenn =, right? 23 MR. PAGLIUCA: Object to form and 24 foundation. 25 THE WITNESS: Fifth.¶
1 .1. Epstein - Confidential 2 THE WITNESS: Fifth. 3 BY MR. CASSELL: 4 Q. You have undertaken no steps to search your 5 e-mail accounts for communications with Ms. Maxwell, 6 right? 7 MR. PAGLIUCA: Object to form and 8 foundation. 9 THE WITNESS: Fifth. 10 BY MR. CASSELL: 11 Q. It would be a simple task for you to search 12 your e-mail accounts for documents associated with 13 communications with Maxwell. right? 14 MR. PAGLIUCA: Object to form and 15 foundation. 16 THE WITNESS: Fifth. 17 BY MR. CASSELL: 18 Q. You have seen Ms. Maxwell commit crimes, 19 right? 20 MR. PAGLIUCA: Object to form and 21 foundation. 22 THE WITNESS: Fifth. 23 BY MR. CASSELL: 24 Q. Miss Maxwell has discussed with you crimes 25 she has committed, right?¶
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 J. Epstein - Confidential BY MR. CASSELL: Q. Who is Renaldo Rizzo? A. Fifth. Q. In about 2005, it's true, sir, that Rizzo observed you and Maxwell in the presence of a - presence of a 15-year-old Swedish girl named Caroline, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. Please describe everything you know about a 15-year-old Swedish girl named Caroline that you interacted with in 2005? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. You and Maxwell brought Caroline over to the United States under false pretenses, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. How did you and Maxwell convince Caroline
4 to come over from Sweden?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. The reason you and Maxwell brought Caroline
10 over from Sweden was to have sex with you, right?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. Did Caroline want to have sex with you?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. What did you do to Caroline when she
21 refused to have sex with you?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. What did Maxwell do to Caroline when you
4 refused -- when she refused to have sex with you?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. Isn't it true, sir, that you tried to force
10 Caroline to have sex with you?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. And isn't it true you coordinated with
16 Maxwell to try to force Caroline to have sex with
17 you?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. Who held Caroline's passport when she came
23 over from Sweden?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. Isn't it true, sir, that Maxwell held
5 Caroline's passport?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Isn't it true, sir, that Maxwell was
11 denying Caroline access to her passport in order to
12 try to force her to have sex with you?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. Why was Maxwell holding onto Caroline's
18 passport?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. What devices did you use -- try to use --
24 strike that.
25 How did you try to force this 15-year-old¶
1 J. Epstein - Confidential
2 girl to have sex with you?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. Was Rizzo present at a time when you were
8 petting like a cat a girl who was a pre-teenage girl?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. Please describe all the times in which you
14 have petted like a cat pre-teenage girls.
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. Was Rizzo present when you had a young girl
20 on your lap?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. Rizzo was telling the truth when he says¶
1 J. Epstein - Confidential
2 you were petting a girl like a cat, wasn't he?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. You and Ms. Maxwell have had sex with a
8 woman named Johanna Sjorberg, right?
9 MR. PAGLIUCA: Object to the form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. Please describe all of your interactions
14 with Johanna Sjorberg.
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. Please describe all of Miss Maxwell's inter
20 actions with Johanna Sjorberg.
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. Sir, it's true that Ms. Maxwell lured¶
1 J. Epstein - Confidential
2 Sjorberg from her school under the guise of needing
3 someone to answer phones, right?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. When Miss Maxwell first interacted with
9 Sjorberg, Maxwell's real purpose was to try to get
10 Sjorberg to have sex with you, right?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. In 2005, Maxwell was around your Florida
16 mansion frequently, right?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. Tell me everything you know about a man
22 name Tony [REDACTED].
23 A. Fifth.
24 Q. You asked a man named Tony [REDACTED] to
25 arrange for underage girls to come over to your home¶
1 J. Epstein - Confidential
2 for sexual purposes, right?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. Ms. Maxwell helped to coordinate the
8 arrival of girls that [REDACTED] brought over to your
9 house, right?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. Please describe all interactions that you
15 are aware of between Ms. Maxwell and Tony [REDACTED].
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. You've had sex with a girl named
21 [REDACTED] right?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Who is [REDACTED]
4 A. Fifth.
5 Q. You had sex with [REDACTED] when she was
6 under the age of 18, right?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. Ms. Maxwell arranged for you to have sex
12 with [REDACTED] when she was under the age of 18,
13 right?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Please describe the circumstances that led
19 you to have sex with [REDACTED].
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. Please describe all interactions between
25 [REDACTED] and Ghislaine Maxwell.¶
1 J. Epstein - Confidential 2 MR. PAGLIUCA: Object to form and 3 foundation. 4 THE WITNESS: Fifth. 5 BY MR. CASSELL: 6 Q. You've had sex with a female named 7 when she was under the age of 18. right? 8 MR. PAGLIUCA: Object to form and 9 foundation. 10 THE WITNESS: Fifth. 11 BY MR. CASSELL: 12 Q. Please describe all of your interactions 13 with 14 MR. PAGLIUCA: Object to form and 15 foundation. 16 THE WITNESS: Fifth. 17 BY MR. CASSELL: 18 Q. Please describe all of Maxwell's 19 interactions with 20 MR. PAGLIUCA: Object to form and 21 foundation. 22 THE WITNESS. Fifth. 23 BY MR. CASSELL: 24 Q. It would be a fair description to sa that 25 you and Maxwell were grooming to be a sex¶
1 J. Epstein - Confidential 2 slave for you, right? 3 MR. PAGLIUCA: Object to form and 4 foundation. 5 THE WITNESS: Fifth. 6 BY MR. CASSELL: 7 . Wh were you and Maxwell interacting with 8 9 . AGLIUCA: Object to form and 10 foundation. 11 THE WITNESS: Fifth. 12 BY MR. CASSELL: 13 . Both you and Maxwell have had sex with 14 right? 15 . AGLIUCA: Object to form and 16 foundation. 17 THE WITNESS: Fifth. 18 BY MR. CASSELL: 19 . You remain on friendly terms with 20 right? 21 . AGLIUCA: Object to form and 22 foundation. 23 THE WITNESS: Fifth. 24 BY MR. CASSELL: 25 Q. If were to appear at trial and¶
1 J. Epstein - Confidential 2 testify, she would have to testify that she is aware 3 of sexual abuse by you of minor girls, right? 4 MR. PAGLIUCA: Object to form and 5 foundation. 6 THE WITNESS: Fifth. 7 BY MR. CASSELL: 8 Q. Does have any knowledge of your 9 sexual abuse lWrage girls? 10 MR. PAGLIUCA: Object to form and 11 foundation. 12 THE WITNESS: Fifth. 13 BY MR. CASSELL: 14 Q. It's true, sir, that does have 15 knowledge that you sex!". underage girls, 16 right? 17 MR. PAGLIUCA: Object to form and 18 foundation. 19 THE WITNESS: Fifth. 20 BY MR. CASSELL: 21 Q. It's true, sir, that has 22 knowledge that Maxwell was involved in the sexual 23 abuse of underage girls? 24 MR. PAGLIUCA: Object to form and 25 foundation.¶
1 J. Epstein - Confidential 2 THE WITNESS: Fifth. 3 BY MR. CASSELL: 4 Q. To your knowledge, what does Maxwell -- I'm 5 sorry. 6 To your knowledge. what does - 7 know about Maxwell's sexual abuse of underage girls? 8 MR. PAGLIUCA: Object to form and 9 foundation. 10 THE WITNESS: Fifth. 11 BY MR. CASSELL: 12 Q. Sir, you are aware that in about January 13 of 2015, Maxwell told the media that Virginia's 14 allegations about sexual abuse were obvious lies, 15 right? 16 MR. PAGLIUCA: Object to form and 17 foundation. 18 THE WITNESS: Fifth. 19 BY MR. CASSELL: 20 Q. In fact, you are not aware of any 21 significant thing that Virginia has said, which is an 22 obvious lie, right? 23 MR. PAGLIUCA: Object to form and 24 foundation. 25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Please list any lies that, sitting here
4 today, you're aware of that Virginia has ever told.
5 A. Fifth.
6 Q. You're unwilling to identify any lies that
7 Virginia has ever told, right?
8 A. Fifth.
9 Q. In fact, you are unable to list any
10 significant lies that Virginia has ever told?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. Without regard to any sexual abuse that you
16 may or may not have committed in the past, do you
17 agree that it is psychologically harmful for an adult
18 male to have sex with a minor female?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. What sort of psychological impact do you
24 think it would have for a 40-year-old man to have sex
25 with a 17-year-old girl?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. What kind of psychological impact do you
7 think it would have for a 40-year-old -- a man in his
8 40s to have sex with a 16-year-old girl?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. You would agree that calling someone a liar
14 when they're telling the truth can cause
15 psychological harm, right?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. What kind of impact would calling someone a
21 liar when they are actually telling the truth?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. You know [REDACTED], right?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. Based on your interactions with
9 [REDACTED], what sort of psychological impact
10 do you think it had when she was called a liar by
11 Maxwell?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. It would have a significant psychological
17 harm on [REDACTED] for Maxwell to call her a
18 liar about true statements, right?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Please tell me everything you know about
24 [REDACTED].
25 A. Fifth.¶
1 J. Epstein - Confidential
2 Q. Please tell me everything you know about
3 [REDACTED].
4 A. Fifth.
5 Q. Both you and Maxwell have had sex with
6 [REDACTED], right?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. Both you and Maxwell have had sex with
12 [REDACTED]?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. Please describe the role that [REDACTED]
18 played in your sex trafficking organization.
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. What did [REDACTED] do for you in 2005?
24 MR. PAGLIUCA: Object to form and
25¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. In the years 2000 and 2001, what did
6 [REDACTED] do for you?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. It's true, sir, that in 2000 and 2001
12 [REDACTED] assisted you in recruiting girls for
13 sexual purposes, right?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. In 2000 and 2001, [REDACTED] assisted
19 you in obtaining girls for sexual purposes, true?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. Who did [REDACTED] report to when she
25 worked for you?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. [REDACTED] reported to
7 Ghislaine Maxwell when she worked for you, right?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. Who did [REDACTED] report to when she
13 worked for you?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. [REDACTED] reported to Ghislaine Maxwell
19 when she worked for you, right?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. [REDACTED] and [REDACTED] sexually
25 abused under age girls in your presence, right?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. [REDACTED] and [REDACTED] are aware
7 of your sexual abuse of underage girls, right?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. Have you ever discussed the lawful age of
13 consent with Ghislaine Maxwell?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. What is your understanding of the age of
19 consent in Florida?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. You've discussed the age of consent in
25 Florida with Maxwell, right?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. What are the circumstances surrounding your
7 discussions with Maxwell of the age of consent in
8 Florida?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. In fact, you and Maxwell were discussing
14 the age of consent in Florida to try to make it
15 appear as though you were having sex with girls who
16 are above the age of consent other than below the age
17 of consent?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. Have you ever threatened
23 Alfredo Rodriguez?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. In fact, you arranged for Alfredo Rodriguez
5 to be threatened by Maxwell, right?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. In 2009, your attorneys attended a
11 deposition of Alfredo Rodriguez, right?
12 A. Fifth.
13 Q. At that time, it was in your interest to
14 limit the ways in which Rodriguez could expose the
15 sex abuse of both you and Maxwell, right?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. When Rodriguez was describing Maxwell's
21 involvement with underage girls, your attorneys had
22 an interest in attacking that testimony, right?
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 MR. WEINBERG: Attorney-client¶
1 J. Epstein - Confidential
2 privilege.
3 THE WITNESS: Fifth.
4 MR. WEINBERG: If the information came
5 from attorneys.
6 MR. CASSELL: Could we take a short
7 break at this time?
8 VIDEO TECHNICIAN: Off the record at
9 11:35.
10 (A recess was taken.)
11 VIDEO TECHNICIAN: Beginning of disc
12 three. On the record at 11:50.
13 BY MR. CASSELL:
14 Q. Sir, I want to represent to you that on
15 about January 2nd, 2015, Defendant Maxwell released a
16 statement that said, "The allegations made by
17 [REDACTED] against Ghislaine Maxwell are
18 untrue."
19 That was a false statement, right?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. In fact, the allegations made by
25 [REDACTED] against Ghislaine Maxwell were true?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. Allegations Virginia made had never been
7 shown to be untrue, had they?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. I'll represent to you that Ms. Maxwell
13 released a statement that said, "Each time the story
14 is retold it changes with new salacious details about
15 public figures and world leaders." And then there's
16 some additional language.
17 You had, in fact, sexually trafficked
18 Virginia to public figures?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. In fact, you had trafficked Virginia to
24 world leaders, right?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. And Maxwell had assisted you in trafficking
6 Virginia to public figures and world leaders?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. Please describe the public figures you and
12 Maxwell and Virginia interacted with.
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. Please describe the world leaders you and
18 Virginia and Maxwell interacted with.
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. I represent to you that around January 2nd,
24 2015, Ms. Maxwell released this statement that
25 "[REDACTED] claims are obvious lies and should be¶
1 J. Epstein - Confidential
2 treated as such." Then there's some additional
3 language.
4 That statement by Ms. Maxwell was, in fact,
5 itself an obvious lie, right?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Miss Maxwell's reference to "obvious lies"
11 was inaccurate, right?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. In fact, given your detailed knowledge of
17 all the circumstances of the case, you know that that
18 was an obvious lie by Maxwell, right?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Is it true that [REDACTED] claims are
24 obvious lies?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. In fact, it is not true that [REDACTED]
6 claims are obvious lies?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 BY MR. CASSELL:
10 Q. Answer?
11 A. You didn't ask me a question.
12 Q. In fact, it is not true that [REDACTED]
13 claims are obvious lies, right?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Prince Andrew visited your New York
19 mansion, right?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. That visit occurred shortly after the
25 events depicted in the photograph we looked at¶
1 J. Epstein - Confidential
2 earlier?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. So that would have been in about March or
8 April of 2001 that Prince Andrew visited you in your
9 New York mansion?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. Has Prince Andrew ever visited you in your
15 New York mansion?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. When Prince Andrew visited you in your New
21 York Mansion, Maxwell was there, right?
22 A. Fifth.
23 Q. Who was in your New York mansion when
24 Maxwell -- I'm sorry, when Prince Andrew visited?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. Prince Andrew interacted with Virginia in
6 your New York mansion, right?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. Maxwell was present when Prince Andrew
12 interacted with Virginia in your New York mansion,
13 right?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. There was a puppet in the room when Maxwell
19 and Virginia and Prince Andrew were all together in
20 your New York mansion?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. A puppet was used to fondle the breasts of¶
1 J. Epstein - Confidential
2 girls under the age of 18, right?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. Who fondled the breasts of underage girls
8 in your New York mansion with a puppet?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. To your knowledge, Prince Andrew had sex
14 with Virginia several times, right?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. [REDACTED] was controlled by
20 Ghislaine Maxwell, right?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. We talked about the timeframe 2000 to 2001.¶
1 J. Epstein - Confidential
2 Who controlled [REDACTED]?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. In 2000 to 2001, Maxwell controlled
8 [REDACTED], right?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. In fact, [REDACTED] remains indebted
14 to Maxwell even today, right?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. In fact, [REDACTED] remains indebted to
20 Maxwell even today, right?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. Describe -- describe the relationship¶
1 J. Epstein - Confidential
2 between [REDACTED] and Ghislaine Maxwell.
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. In 2000 to 2001, [REDACTED] was
8 controlled by Ghislaine Maxwell, right?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. Please describe all of the relationships
14 Ghislaine Maxwell has with your companies and
15 businesses.
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. In fact, Maxwell has been a partner with
21 you in several of your business enterprises, right?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. You continue to have a very close working
4 relationship with Maxwell today, right?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. You and Maxwell have been coordinating
10 together on this litigation, right?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. You hope that Maxwell prevails in this
16 litigation, right?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. You and Ghislaine Maxwell regularly
22 transported girls across state lines for sexual
23 purposes, right?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. Please describe all the situations in which
5 you and Maxwell have been involved in the interstate
6 transportation of girls under the age of 18.
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. You have used cell phones and land line
12 cell phone -- land line telephones to instruct
13 [REDACTED] to have sex, right?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. You've given instructions by telephone to
19 [REDACTED] to have sex with people while she is
20 under the age of -- while she was under the age of
21 18, right?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. You have instructed girls under the age of
4 18 via telephone and cell phone to have sex with men,
5 right?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. You've instructed girls under the age of 18
11 by telephone to have sex with various of your
12 friends, right?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. Have you ever threatened a witness not to
18 talk?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Has Ghislaine Maxwell ever threatened a
24 witness not to talk?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. In fact, you have threatened witnesses not
6 to talk, right?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. In fact, Ghislaine Maxwell has threatened
12 witnesses not to talk, right?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. In about 2007, you arranged to have someone
18 hunt down and find Virginia, right?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. How did you find Virginia in 2007?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. The reason you needed to find Virginia in
5 2007 was because the FBI had opened an investigation
6 on you, right?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. When was the last time you spoke to
12 [REDACTED]?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Who?
16 BY MR. CASSELL:
17 Q. Miss [REDACTED] --
18 A. Sorry. Sorry.
19 Q. -- [REDACTED], I should say.
20 Yeah.
21 A. Fifth.
22 Q. When was the last time you spoke to
23 Virginia?
24 A. Fifth.
25 Q. In fact, you and your attorney actually got¶
1 J. Epstein - Confidential
2 together on the phone with Virginia in about 2007,
3 right?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. Which of your attorneys was on the phone
9 with Virginia in about 2007?
10 A. Fifth.
11 Q. Was it Mr. Goldberger?
12 MR. WEINBERG: Attorney-client.
13 MR. GOLDBERGER: And attorney-client.
14 I apologize. I'm sorry.
15 BY MR. CASSELL:
16 Q. This is -- I'm talking about a telephone
17 call where there was a third party. [REDACTED]
18 [REDACTED], on the phone.
19 That was Mr. Goldberger on the phone?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 MR. GOLDBERGER: And attorney-client
24 privilege.
25¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. During the call, Mr. Epstein, you asked
4 Virginia if she was going to say anything to the FBI,
5 right?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. The clear implication of your question what
11 to Virginia was that she should not say anything to
12 the FBI, right?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. You told Virginia directly or indirectly
18 was the best thing for her and her family was to keep
19 quiet, right?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. What did you tell Virginia in 2007 when you
25 were on the phone with an attorney?¶
1 J. Epstein - Confidential
2 A. Fifth.
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 BY MR. CASSELL:
6 Q. You suggested that those who talked to the
7 FBI would be harmed, all those who did not, would be
8 helped, right?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. And those communications you had with
14 Virginia in 2007 influenced the settlement of
15 Virginia's civil case against you in 2009?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. The first time you met Virginia
21 Ghislaine Maxwell came up to the room with you as
22 well, right?
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Please describe who was in the room, your
4 massage room, the first time you met
5 [REDACTED]
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Ghislaine Maxwell participated in the
11 sexual abuse of Virginia the first time she came over
12 to your house, right?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. What kind of instructions did Maxwell give
18 Virginia when you first met Virginia?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. In fact, Maxwell instructed Virginia how to
24 sexually please you the first time she met you,
25 right?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 MR. CASSELL: Those are my questions at
6 this point. I understand Mr. Pagliuca may
7 have some questions, and I'll have some
8 follow-up based on that.
9 MR. GOLDBERGER: Okay. So why don't we
10 take ten or 15. You guys can eat your
11 lunch, and we'll go into my office. And
12 about ten, 15-minutes we'll come in.
13 THE WITNESS: It's 12 now. 12:15 come
14 back?
15 MR. CASSELL: That's fine.
16 VIDEO TECHNICIAN: Off the record at
17 12:00 o'clock.
18 (A lunch recess was taken.)
19 A F T E R N O O N S E S S I O N
20 - - -
21 VIDEO TECHNICIAN: On the record at
22 12:21.
23 MR. GOLDBERGER: Jeffrey, before you
24 ask your question, did -- did we reach the
25 same agreement with you that we did with¶
1 J. Epstein - Confidential
2 Mr. Cassell concerning the more -- the
3 longer Fifth Amendment invocation?
4 MR. PAGLIUCA: Yes. In the beginning
5 of the deposition I indicated that that was
6 perfectly acceptable with me.
7 MR. GOLDBERGER: Okay.
8 MR. PAGLIUCA: And I'm also happy,
9 Mr. Cassell, if you want to make form and
10 foundation objections, I will understand
11 that that encompasses the totality of the
12 objections.
13 MR. CASSELL: All right.
14 CROSS-EXAMINATION
15 BY MR. PAGLIUCA:
16 Q. Good afternoon, Mr. Epstein. My name is
17 Jeff Pagliuca.
18 We have never met before, correct?
19 A. Correct.
20 Q. Mr. Epstein, you were asked a number of
21 leading questions by Mr. Cassell this morning and
22 into this afternoon.
23 You understand what a leading question is,
24 correct?
25 A. Fifth.¶
1 J. Epstein - Confidential
2 Q. In fact, the question I just asked you was
3 a leading question, as an example, correct?
4 A. Fifth.
5 Q. You would agree with me that Mr. Cassell's
6 questions about Ms. Maxwell had no basis in fact,
7 correct?
8 MR. CASSELL: Objection to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. PAGLIUCA:
12 Q. You would agree with me that the purported
13 factual basis underlying Mr. Cassell's questions did
14 not occur, correct?
15 MR. CASSELL: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. PAGLIUCA:
19 Q. And you would agree with me that had you
20 been able to answer Mr. Cassell's questions, your
21 answers would have supported Ms. Maxwell in this
22 litigation and not supported the Plaintiff, correct?
23 MR. CASSELL: Object to form and
24 foundation, and calls for a legal
25 conclusion.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. PAGLIUCA:
4 Q. In fact, had you been able to answer, you
5 would have denied any sexual impropriety with the
6 Plaintiff in this case, formerly [REDACTED], now
7 [REDACTED], correct?
8 MR. CASSELL: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. PAGLIUCA:
12 Q. And you would have denied any sexual
13 impropriety with any other individuals in answer to
14 Mr. Cassell's questions had you been able to answer,
15 correct?
16 MR. CASSELL: Form and foundation.
17 THE WITNESS: Fifth.
18 BY MR. PAGLIUCA:
19 Q. Mr. Cassell asked you some questions about
20 your financial status. I'm going to repeat a couple
21 of those briefly.
22 You would agree with me that you are a very
23 wealthy man, correct, Mr. Epstein?
24 A. Fifth.
25 MR. CASSELL: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Sorry.
4 BY MR. PAGLIUCA:
5 Q. You would agree with me that you do not
6 depend on Ghislaine Maxwell for any financial
7 support, correct?
8 MR. CASSELL: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. PAGLIUCA:
12 Q. You do not have any business relationship
13 with Ghislaine Maxwell, correct?
14 MR. CASSELL: Object to form and
15 foundation and vague.
16 THE WITNESS: Fifth.
17 BY MR. PAGLIUCA:
18 Q. You do not have any social relationship
19 with Ghislaine Maxwell, correct?
20 MR. CASSELL: Object to form and
21 foundation and vague.
22 THE WITNESS: Fifth.
23 BY MR. PAGLIUCA:
24 Q. All right. You have not spoken to
25 Ghislaine Maxwell in many years, correct?¶
1 J. Epstein - Confidential
2 MR. CASSELL: Object to form and
3 foundation, and vague as to what the term
4 "spoken" means.
5 THE WITNESS: Fifth.
6 BY MR. PAGLIUCA:
7 Q. You've not had any verbal communication,
8 meaning oral, with Ms. Maxwell for many years,
9 correct?
10 MR. CASSELL: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. PAGLIUCA:
14 Q. You have not physically seen Ms. Maxwell in
15 many years, correct?
16 A. Fifth.
17 Q. You have not --
18 MR. CASSELL: I'm sorry. I missed the
19 -- form and foundation objection.
20 BY MR. PAGLIUCA:
21 Q. You have not been in any location
22 contemporaneously with Ms. Maxwell in many years,
23 correct?
24 MR. CASSELL: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. PAGLIUCA:
4 Q. Any relationship you had, whether personal
5 or business, ended with Ms. Maxwell more than
6 15 years ago, correct?
7 MR. CASSELL: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. PAGLIUCA:
11 Q. Ms. Maxwell is not --
12 MR. CASSELL: I'm sorry. Could you
13 mark that question for me as well? The last
14 one.
15 BY MR. PAGLIUCA:
16 Q. Ms. Maxwell is not an employee of yours,
17 correct?
18 MR. CASSELL: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. PAGLIUCA:
22 Q. Ms. Maxwell is not an agent of yours,
23 correct?
24 MR. CASSELL: Object to form and
25 foundation. Calls for a legal conclusion.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. PAGLIUCA:
4 Q. Ms. -- Ms. Maxwell -- you are not an agent
5 of Ms. Maxwell's, correct?
6 MR. CASSELL: Object to form and
7 foundation. Calls for a legal conclusion.
8 THE WITNESS: Fifth.
9 BY MR. PAGLIUCA:
10 Q. Ms. Maxwell has never authorized you to act
11 on her behalf, correct?
12 MR. CASSELL: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 BY MR. PAGLIUCA:
16 Q. Ms. Maxwell does not control any of your
17 decisions in any way --
18 MR. CASSELL: Object to form --
19 BY MR. PAGLIUCA:
20 Q. -- correct?
21 MR. CASSELL: Sorry. Object to form
22 and foundation.
23 THE WITNESS: Fifth.
24 BY MR. PAGLIUCA:
25 Q. Do you understand that Ms. Maxwell opposes¶
1 J. Epstein - Confidential
2 you asserting any Fifth Amendment privilege in this
3 matter?
4 MR. CASSELL: Objects to form -- object
5 and foundation.
6 THE WITNESS: Fifth.
7 BY MR. PAGLIUCA:
8 Q. Do you understand that Ms. Maxwell believes
9 that your truthful testimony in this case would be
10 helpful to her?
11 MR. CASSELL: Object to form and
12 foundation. Calls for speculation.
13 THE WITNESS: Fifth.
14 BY MR. PAGLIUCA:
15 Q. You indicated earlier that you and I have
16 never met.
17 You and I have never spoken prior to today,
18 correct?
19 MR. CASSELL: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. PAGLIUCA:
23 Q. You have never spoken to any member of my
24 law firm prior to today, correct?
25 MR. CASSELL: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. PAGLIUCA:
5 Q. In 2009, you entered into a settlement
6 agreement with [REDACTED], formerly known as
7 [REDACTED], the Plaintiff in this case, correct?
8 MR. CASSELL: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 MR. GOLDBERGER: And attorney-client
12 privilege. And to the extent that there's
13 an agreement that exists that's
14 confidential, we will not waive the
15 confidentiality agreement.
16 MR. PAGLIUCA: And we can have -- you
17 can have a standing objection to that on
18 those grounds related to any question I ask
19 about the settlement agreement with
20 [REDACTED], if that makes it easier.
21 MR. GOLDBERGER: Yeah. That makes it
22 easier. Thank you.
23 BY MR. PAGLIUCA:
24 Q. I've not seen the settlement agreement.
25 But let me ask you if you can tell me what the terms¶
1 J. Epstein - Confidential
2 of that agreement are, Mr. Epstein.
3 MR. CASSELL: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. PAGLIUCA:
7 Q. Does the settlement agreement contain a
8 release of any claims that [REDACTED] had or would
9 have against you?
10 MR. CASSELL: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. PAGLIUCA:
14 Q. Did the settlement agreement provide for a
15 release by you of any claims against [REDACTED]?
16 MR. CASSELL: Form and foundation.
17 THE WITNESS: Fifth.
18 BY MR. PAGLIUCA:
19 Q. It's true, is it not, Mr. Epstein, you have
20 no economic interest in this litigation?
21 MR. CASSELL: Form and foundation.
22 Calls for a legal conclusion.
23 THE WITNESS: Fifth.
24 BY MR. PAGLIUCA:
25 Q. And by "this litigation," I mean the¶
1 J. Epstein - Confidential
2 litigation we are here on today, the Plaintiff being
3 [REDACTED], the Defendant being Ms. Maxwell.
4 So, to be clear, you are not named as a
5 Defendant in that litigation, correct?
6 MR. CASSELL: Form and foundation.
7 THE WITNESS: Fifth.
8 BY MR. PAGLIUCA:
9 Q. The outcome of this litigation, the [REDACTED]
10 versus Maxwell litigation, will have no impact on you
11 financially, correct?
12 MR. CASSELL: Form and foundation.
13 THE WITNESS: Fifth.
14 BY MR. PAGLIUCA:
15 Q. And the outcome of -- of this litigation
16 will not affect you in any way, correct?
17 MR. CASSELL: Form and foundation.
18 THE WITNESS: Fifth.
19 BY MR. PAGLIUCA:
20 Q. In 2007 you entered into what's been
21 referred to here today as a non-prosecution agreement
22 with the United States Government; is that correct?
23 A. Fifth.
24 Q. And as part of that non-prosecution
25 agreement, the United States of America agreed to not¶
1 J. Epstein - Confidential
2 institute criminal charges against alleged potential
3 co-conspirators in that matter, including
4 [REDACTED], Leslie Goth (phonetic),
5 or [REDACTED]; is that correct?
6 MR. CASSELL: Form and foundation.
7 Calls for a legal conclusion.
8 MR. WEINBERG: To the extent your
9 knowledge is based on communications with
10 attorneys, attorney-client privilege.
11 THE WITNESS: Fifth.
12 BY MR. PAGLIUCA:
13 Q. You were provided, Mr. Epstein, with a copy
14 of the non-prosecution agreement that you entered
15 into with the United States Government in 2007,
16 correct?
17 A. Fifth.
18 MR. WEINBERG: Attorney-client
19 privilege.
20 BY MR. PAGLIUCA:
21 Q. And you've read a non-prosecution agreement
22 that you entered into with the United States
23 Government in 2007 before you signed it, correct?
24 A. Fifth.
25 Q. Ms. Maxwell was not identified by name in¶
1 J. Epstein - Confidential
2 the non-prosecution agreement, correct?
3 A. Fifth.
4 Q. And Ms. Maxwell was not identified in the
5 non-prosecution agreement because she was not a
6 conspirator in any crime, correct?
7 MR. CASSELL: Form and foundation.
8 Calls for a legal conclusion.
9 THE WITNESS: Fifth.
10 BY MR. PAGLIUCA:
11 Q. You are aware, from sources other than your
12 lawyers, that Mr. [REDACTED], who is one of the
13 Plaintiff's lawyers in this case, and Mr. Cassell,
14 who has taken your deposition here today, are
15 attempting to have your non-prosecution agreement
16 with the United States Government voided, correct?
17 A. Fifth.
18 MR. CASSELL: Object to form and
19 foundation.
20 MR. GOLDBERGER: And attorney-client
21 privilege.
22 BY MR. PAGLIUCA:
23 Q. Absent the attempts by Mr. Cassell and
24 [REDACTED] on behalf of their clients to void your
25 non-prosecution agreement, you would be available as¶
1 J. Epstein - Confidential
2 a witness to testify in this case, correct?
3 A. Fifth.
4 MR. CASSELL: Object to form and
5 foundation. Calls for a legal conclusion.
6 MR. WEINBERG: The answer would be
7 based on the attorney-client privilege
8 communication.
9 MR. GOLDBERGER: I think he said, the
10 Fifth.
11 THE COURT REPORTER: Okay.
12 THE WITNESS: Fifth.
13 BY MR. PAGLIUCA:
14 Q. And setting aside any communications that
15 you may have had with any lawyers representing you,
16 absent the efforts by Mr. Cassell and [REDACTED] to have
17 your non-prosecution agreement voided, you would be
18 able to testify as a witness in this matter, correct?
19 MR. CASSELL: Form and foundation.
20 Calls for a legal conclusion.
21 THE WITNESS: Fifth.
22 BY MR. PAGLIUCA:
23 Q. Absent the efforts by Mr. Cassell and
24 Mr. [REDACTED] to void your non-prosecution agreement,
25 you would be willing to testify as a witness in this¶
1 J. Epstein - Confidential
2 case, correct?
3 MR. CASSELL: Form and foundation.
4 Speculation.
5 THE WITNESS: Fifth.
6 BY MR. PAGLIUCA:
7 Q. And absent the efforts by Mr. Cassell and
8 Mr. [REDACTED] to void your non-prosecution agreement,
9 your willing, truthful testimony in this case would
10 be helpful to Ms. Maxwell, correct?
11 MR. CASSELL: Form. Foundation. Calls
12 for a legal conclusion. Speculation.
13 THE WITNESS: Fifth.
14 BY MR. PAGLIUCA:
15 Q. You were asked some questions by
16 Mr. Cassell about the lawsuit by [REDACTED] against
17 you.
18 It's true, is it not, that the allegations
19 contained in that complaint against you by Ms. --
20 then [REDACTED] or [REDACTED] were false, correct?
21 MR. CASSELL: Form. Foundation.
22 THE WITNESS: Fifth.
23 BY MR. PAGLIUCA:
24 Q. And any allegations in that complaint by
25 [REDACTED] against you relating to¶
1 2 3 4 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 J. Epstein - Confidential Ms. Maxwell were false, correct? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. Can you tell me, Mr. Epstein, given that the allegations against you in the complaint by were false, why did you settle the lawsuit? MR. CASSELL: Form. Foundation. MR. GOLDBERGER: And attorney-client privilege. MR. WEINBERG: Attorney-client privilege. Sorry, Jack. MR. GOLDBERGER: That's okay. Marty. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. And without regard -- so I'm not asking you for any communication between you and any lawyer. Given the fact that the allegations given by Miss nil against you were false, without discussing any information communicated to you by any lawyer, what were your personal reasons for settling the lawsuit? MR. CASSELL: Form. Foundation.¶
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 J. Epstein - Confidential THE WITNESS: Fifth. MR. WEINBERG: And his -- and his state of mind is inseparable from attorney-client communications. MR. PAGLIUCA: Right. I'm not asking for any attorney-client communications, so we are clear. BY MR. PAGLIUCA: Q. I don't recall if I asked you or not, but I will ask you now: What were the terms of the settlement agreement between yourself and A. Fifth. MR. GOLDBERGER: And the standing objection on confidentiality. MR. PAGLIUCA: Understood. BY MR. PAGLIUCA: Mr. Epstein. you read statements published in the media about Ghislaine Maxwell, correct? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. When you read those statements, you¶
- J. Epstein - Confidential 2 understood that the statements made about Ms. Maxwell 3 were false, correct? 4 MR. CASSELL: Form. Foundation. 5 THE WITNESS: Fifth. 6 BY MR. PAGLIUCA: 7 Q. You understood that those statements were 8 false because Ms. Maxwell did not recruit 9 to have sex with you. correct? 10 MR. CASSELL: Form. Foundation. 11 THE WITNESS: Fifth. 12 BY MR. PAGLIUCA: 13 Q. You understood that the statements were 14 false because Ms. Maxwell did not assist anyone. 15 includin ourself, in sexually trafficking 16 to any person, correct? 17 MR. CASSELL: Object to form and 18 foundation. And just so the record is 19 clear. if I just use the words "form. 20 foundation" -- 21 MR. PAGLIUCA: That is fine with me. 22 MR. CASSELL: Form. Foundation. 23 THE WITNESS: Fifth. 24 BY MR. PAGLIUCA: 25 Q. You understand that was
1 2 3 4 5 6 7 8 9 10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 J. Epstein - Confidential not 15 when she claims to have met you, true? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. You understand that was not 16 at the time that she claims to have met you, correct? MR. CASSELL: Form, foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: . You understand -- well, isn't it true that represented to you, at the time that she met you, that she was 18 years old? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. Isn't it true that represented to others in your presence that she was over the age of 18? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. Isn't it true that represented to Ms. Maxwell that she was over the age of 18?¶
1 J. Epstein - Confidential
2 MR. CASSELL: Form. Foundation.
3 THE WITNESS: Fifth.
4 BY MR. PAGLIUCA:
5 Q. Mr. Cassell asked you some questions about
6 a purported hospital visit involving you and
7 [REDACTED] in New York.
8 Do you recall that, if you know, that
9 [REDACTED] represented to the hospital folks that
10 she was over the age of 18?
11 MR. CASSELL: Form. Foundation.
12 THE WITNESS: Fifth.
13 BY MR. PAGLIUCA:
14 Q. Now, when you met [REDACTED], in
15 addition to telling you that she was over the age of
16 18, she represented to you that she worked as a
17 masseuse at Mar-a-Lago, correct?
18 MR. CASSELL: Form. Foundation.
19 THE WITNESS: Fifth.
20 BY MR. PAGLIUCA:
21 Q. And you would have met her sometime in the
22 late fall because Mar-a-Lago is closed, at least the
23 spa part of Mar-a-Lago is closed, during the summer,
24 correct?
25 MR. CASSELL: Form. Foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. PAGLIUCA:
4 Q. And in 2000, 2001, the spa would have been
5 closed during the summer, correct?
6 MR. CASSELL: Form. Foundation.
7 THE WITNESS: Fifth.
8 BY MR. PAGLIUCA:
9 Q. It was your decision to hire [REDACTED] as
10 a masseuse, understanding that she was over the age
11 of 18, correct?
12 MR. CASSELL: Form, foundation.
13 THE WITNESS: Fifth.
14 BY MR. PAGLIUCA:
15 Q. And she was not recruited by you or anyone
16 else to have sex with you, correct?
17 MR. CASSELL: Form. Foundation.
18 THE WITNESS: Fifth.
19 BY MR. PAGLIUCA:
20 Q. Now, at the time that [REDACTED] met you
21 and represented that she was a masseuse and over the
22 age of 18, she was driving her own car, correct?
23 MR. CASSELL: Form, foundation.
24 THE WITNESS: Fifth.
25¶
1 J. Epstein - Confidential
2 BY MR. PAGLIUCA:
3 Q. At the time that [REDACTED] met
4 you and told you that she was over the age of 18 and
5 a masseuse, she was living with someone that she
6 identified as her fiance, correct?
7 MR. CASSELL: Form. Foundation.
8 THE WITNESS: Fifth.
9 BY MR. PAGLIUCA:
10 Q. At the time that [REDACTED] met you --
11 represented to you that she was a masseuse over the
12 age of 18, driving her own car, and living with her
13 fiance in an apartment, she had the ability to come
14 and go from your residence as she pleased, correct?
15 MR. CASSELL: Form. Foundation.
16 THE WITNESS: Fifth.
17 BY MR. PAGLIUCA:
18 Q. You never forced [REDACTED] ever to stay
19 over your house at night, correct?
20 MR. CASSELL: Form. Foundation.
21 Vague.
22 THE WITNESS: Fifth.
23 BY MR. PAGLIUCA:
24 Q. [REDACTED] was never forced to do anything
25 by you, correct?¶
1 J. Epstein - Confidential
2 MR. CASSELL: Form. Foundation.
3 Vague.
4 THE WITNESS: Fifth.
5 BY MR. PAGLIUCA:
6 Q. [REDACTED] was not a "sex slave," correct?
7 MR. CASSELL: Form. Foundation.
8 THE WITNESS: Fifth.
9 BY MR. PAGLIUCA:
10 Q. And you never sexually trafficked
11 [REDACTED] to anyone, correct?
12 MR. CASSELL: Form. Foundation.
13 THE WITNESS: Fifth.
14 BY MR. PAGLIUCA:
15 Q. At the time [REDACTED] made statements to
16 the media about you and Ms. Maxwell, you told
17 Ms. Maxwell on January 25th, 2015, that "You have
18 done nothing wrong, and I would urge you to start
19 acting like it. Go outside, head high, not as an
20 escaping convict. Go to parties. Deal with it."
21 Do you remem- -- recall making that written
22 statement to Ms. Maxwell in an e-mail produced in
23 this case, GM01098, on January 25th, 2015?
24 MR. CASSELL: Form. Foundation.
25 THE WITNESS: Fifth.¶
¶
1 J. Epstein - Confidential¶
2 BY MR. PAGLIUCA:¶
3 Q. And at the time that you made that e-mail
4 statement to Ms. Maxwell, you made it because it was
5 true, correct?¶
6 MR. CASSELL: Form. Foundation.¶
7 THE WITNESS: Fifth.¶
8 BY MR. PAGLIUCA:¶
9 Q. When you said to Ms. Maxwell in your
10 written communication on January 25th, 2015, "You
11 have done nothing wrong," you were referring to
12 [REDACTED] false claims that somehow¶
13 Ms. Maxwell had participated in sexual misconduct
14 with [REDACTED], correct?¶
15 MR. CASSELL: Form. Foundation.¶
16 THE WITNESS: Fifth.¶
17 BY MR. PAGLIUCA:¶
18 Q. When you said to Ms. Maxwell, "You have
19 done nothing wrong," you were telling her that you
20 knew that she had not been involved in any illegal
21 activity associated with you, correct?¶
22 MR. CASSELL: Form. Foundation.¶
23 THE WITNESS: Fifth.¶
24 BY MR. PAGLIUCA:¶
25 Q. You urged Ms. Maxwell to start acting like¶
1 J. Epstein - Confidential¶
2 she had done nothing wrong, because you knew that she
3 had, in fact, done nothing wrong, correct?¶
4 MR. CASSELL: Form. Foundation. Calls
5 for speculation.¶
6 THE WITNESS: Fifth.¶
7 BY MR. PAGLIUCA:¶
8 Q. When you told Ms. Maxwell, "Go outside,
9 head high, not as an escaping convict," you were
10 encouraging her to act like she had done nothing
11 wrong because, in fact, she had done nothing wrong,
12 correct?¶
13 MR. CASSELL: Form. Foundation.¶
14 Vague.¶
15 THE WITNESS: Fifth.¶
16 BY MR. PAGLIUCA:¶
17 Q. You were responding to an e-mail sent to
18 you by Ms. Maxwell on January 24th, 2015, in which
19 she indicated, "I would appreciate it if [REDACTED] would
20 come out and say that she was your girlfriend. I
21 think she was from end '99 to 2002."¶
22 Do you recall receiving that communication
[REDACTED] Maxwell and responding to it?¶
24 MR. CASSELL: Form. Foundation.¶
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential¶
2 BY MR. PAGLIUCA:¶
3 Q. You responded, "Okay, with me," because, in
4 fact, [REDACTED] was your girlfriend from at least the
5 end of 1999 through 2002, correct?¶
6 MR. CASSELL: Form. Foundation.¶
7 THE WITNESS: Fifth.¶
8 BY MR. PAGLIUCA:¶
9 Q. It is true that neither you nor Ms. Maxwell
10 trained [REDACTED] to have sex with anyone,
11 correct?¶
12 MR. CASSELL: Form. Foundation.¶
13 THE WITNESS: Fifth.¶
14 BY MR. PAGLIUCA:¶
15 Q. And it is true that you never pimped
16 [REDACTED] out to any other person,
17 correct?¶
18 MR. CASSELL: Form. Foundation.
19 Vague.¶
20 THE WITNESS: Fifth.¶
21 BY MR. PAGLIUCA:¶
22 Q. To your knowledge, [REDACTED]
23 did not have sex with Alan Dershowitz?¶
24 MR. CASSELL: Form. Foundation.¶
25 BY MR. PAGLIUCA:¶
1 J. Epstein - Confidential¶
2 Q. Correct?¶
3 A. Fifth.¶
4 Q. Any other world leaders, correct?
5 MR. CASSELL: Form. Foundation.¶
6 THE WITNESS: Fifth.¶
7 BY MR. PAGLIUCA:¶
8 Q. Any other political figures in the
9 United States?¶
10 MR. CASSELL: Form. Foundation.¶
11 THE WITNESS: Fifth.¶
12 BY MR. PAGLIUCA:¶
13 Q. Any other entertainers?¶
14 A. Fifth.¶
15 MR. CASSELL: Form. Foundation.¶
16 THE WITNESS: Sorry.¶
17 BY MR. PAGLIUCA:¶
18 Q. In particular, David Copperfield?¶
19 MR. CASSELL: Form. Foundation.¶
20 THE WITNESS: Fifth.¶
21 BY MR. PAGLIUCA:¶
22 Q. You understood that [REDACTED]
23 left the United States in, roughly, 2002 to go to
24 Thailand, correct?¶
25 A. Fifth.¶
1 J. Epstein - Confidential
2 Q. And the last time that you spoke or saw her
3 was prior to her leaving for Thailand, correct?
4 MR. CASSELL: Form. Foundation.
5 THE WITNESS: Fifth.
6 BY MR. PAGLIUCA:
7 Q. You understood that [REDACTED] went to Thailand because she had a warrant out for
8 her arrest for theft from the Roadhouse Grill,
9 correct?
10 MR. CASSELL: Form. Foundation. Calls
11 for a legal conclusion.
12 THE WITNESS: Fifth.
13 BY MR. PAGLIUCA:
14 Q. You were asked some questions by
15 Mr. Cassell regarding the -- I can't recall what he
16 referred to it as. I think it was the Palm Beach
17 investigation.
18 Are you aware that in approximately March
19 of 2005 -- I'm just going to wait for that noise to
20 die down here, whatever that is.
21 You're aware that in approximately March
22 of 2005, the Palm Beach Police Department began an
23 investigation concerning you based on a report from a
24 woman named Erica [REDACTED]?
25¶
1 J. Epstein - Confidential
2 MR. CASSELL: Form. Foundation.
3 MR. GOLDBERGER: And attorney-client
4 privilege.
5 THE WITNESS: Fifth.
6 BY MR. PAGLIUCA:
7 Q. I'm not asking you for any information
8 based on attorney-client privilege, Mr. Epstein, for
9 any of these questions.
10 I'm assuming that you were provided and
11 read police reports related to the Palm Beach
12 investigation. Based on your reading of those
13 reports and not based on any conversations with any
14 lawyers that you may have had at the time, you are
15 aware that in approximately March of 2005, the Palm
16 Beach Police Department began an investigation
17 concerning you based on a report from a woman named
18 Erica [REDACTED]?
19 A. Fifth.
20 Q. You were provided with a copy of the police
21 reports related to that investigation, correct?
22 A. Fifth.
23 MR. GOLDBERGER: And attorney-client
24 privilege.
25¶
1 J. Epstein - Confidential
2 BY MR. PAGLIUCA:
3 Q. The police reports generally indicated that
4 allegations that you had sexual contact with females
5 under the age of 18 in the Palm Beach area, correct?
6 A. Fifth.
7 Q. [REDACTED] was not one of the
8 alleged victims discussed or contacted in connection
9 with that investigation, correct?
10 MR. CASSELL: Form. Foundation.
11 THE WITNESS: Fifth.
12 BY MR. PAGLIUCA:
13 Q. And to your knowledge,
14 [REDACTED] was never contacted by the
15 Palm Beach Police Department?
16 MR. CASSELL: Form. Foundation.
17 Vague.
18 THE WITNESS: Fifth.
19 BY MR. PAGLIUCA:
20 Q. None of the alleged victims in the Palm
21 Beach investigation identified Ghislaine Maxwell as a
22 part of any alleged sexual contact scheme, correct?
23 MR. CASSELL: Form. Foundation.
24 THE WITNESS: Fifth.
25¶
1 J. Epstein - Confidential
2 BY MR. PAGLIUCA:
3 Q. You're aware that no one connected with
4 that investigation accused Ms. Maxwell of any
5 wrongdoing?
6 MR. CASSELL: Form. Foundation.
7 THE WITNESS: Fifth.
8 BY MR. PAGLIUCA:
9 Q. None of the alleged victims in the Palm
10 Beach investigation claimed that they traveled with
11 you in any airplane, correct?
12 A. Fifth.
13 Q. None of the alleged victims in the Palm
14 Beach investigation claimed that they traveled with
15 you outside of the State of Florida, correct?
16 MR. CASSELL: Form. Foundation.
17 THE WITNESS: Fifth.
18 BY MR. PAGLIUCA:
19 Q. None of the alleged victims in the Palm
20 Beach investigation claimed that you have been
21 introduced to them by Ghislaine Maxwell, correct?
22 MR. CASSELL: Form. Foundation.
23 THE WITNESS: Fifth.
24 BY MR. PAGLIUCA:
25 Q. In fact, the majority of the alleged¶
1 2 3 4 J. Epstein - Confidential victims in the Palm Beach investigation claimed to have been recruited by someone named correct?¶
5 MR. CASSELL: Form. Foundation.¶
6 THE WITNESS: Fifth.¶
7 BY MR. PAGLIUCA:¶
8 9 10 Q. You're aware, Mr. Epstein, that these police reports are available as a public record by request to the Palm Beach Police Department?¶
11 A. Fifth.¶
12 Q. And you're aware, Mr. Epstein, that 13 unredacted versions of these police reports can be 13 victims ever claimed to have been paid by 14 obtained from the State's Attorney's Office hereby a 14 Ms. Maxwell? 15 letter request, correct? 15 MR. CASSELL: Form. Foundation.¶
J. Epstein - Confidential¶
you overnight in any residence?¶
MR. CASSELL: Form. Foundation.¶
THE WITNESS: Fifth.¶
BY MR. PAGLIUCA:¶
Q. You're aware that none of those alleged¶
victims claimed to have ever met or talked to¶
Ms. Maxwell?¶
MR. CASSELL: Form. Foundation.¶
THE WITNESS: Fifth.¶
BY MR. PAGLIUCA: Q. And you're aware that none of those alleged¶
16 MR. CASSELL: Form -- form. 16 THE WITNESS: Fifth.¶
17 Foundation. 17 BY MR. PAGLIUCA:¶
18 THE WITNESS: Fifth. 18 Q. It is true, Mr. Epstein, that you. at least 19 BY MR. PAGLIUCA: 19 during timeframe that we are talking about here, so I 20 Q. Mr. Cassell asked you some questions 20 will say from, let's say, 1999 through 2005, enjoyed 21 earlier about some police reports related to 21 getting a massage; is that correct?¶
22 related to her claims that she 22 A. Fifth. 23 had been sexually assaulted here in Florida by men 23 Q. And you had many masseuses that you hired¶
24 other than you. Do you recall those questions? 24 to come to your house to give you a massage, correct?¶
25 A. Yes. 25 MR. CASSELL: Object to form.¶
1 J. Epstein - Confidential 1 J. Epstein - Confidential 2 Q. Okay. Are you aware that those police 2 THE WITNESS: Fifth. 3 reports are also available by simply requesting them 3 BY MR. PAGLIUCA:¶
4 from the Palm Beach Police Department? 4 Q. Many of those masseuses were contacted as¶
5 MR. CASSELL: Form. Foundation. Calls 5 part of the Palm Beach Police Department 6 for a legal conclusion. 6 investigation; do you recall that?¶
7 THE WITNESS: Fifth. 7 A. Fifth.¶
8 MR. CASSELL: Can we hold on one 8 Q. And many of those masseuses that were 9 second? 9 contacted indicated that all of their massages were¶
10 MR. PAGLIUCA: Sure. Having a problem 10 professional and paid for by you; do you recall that? 11 there? 11 MR. CASSELL: Form. Foundation.¶
12 MR. CASSELL: Take 30 seconds to see if 12 THE WITNESS: Fifth. 13 we can get these going. 13 BY MR. PAGLIUCA:¶
14 All right. You're on, Jeff. 14 Q. Now, you -- after left the 15 MR. PAGLIUCA: Okay. 15 country as a result of the warrant out for her arrest 16 BY MR. PAGLIUCA: 16 for theft, you later learned that she was bringing¶
17 Q. With regard to the Palm Beach Police 17 civil claims against you, purporting that you had 18 Department investigation, you're aware that none of 18 sexually assaulted her, correct? 19 the alleged victims in that matter claimed to have 19 MR. CASSELL: Form. Foundation. 20 lived with you? 20 THE WITNESS: Fifth.¶
21 MR. CASSELL: Form. Foundation. 21 BY MR. PAGLIUCA:¶
22 THE WITNESS: Fifth. 22 Q. And those claims were raised up by her 23 BY MR. PAGLIUCA: 23 after a lot of publicity had occurred related to the¶
24 Q. You're aware that none of the alleged 24 Palm Beach investigation about you with the 25 victims in that matter claimed to have stayed with 25 allegations of sexual misconduct, correct?¶
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 J. Epstein - Confidential MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. There were widespread media reports detailing the allegations about you in the press here in the South Florida area at the time, correct? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. Would you agree with me, Mr. Epstein. that the police -- the leaking of the police reports and the leaking of the information to the press. the reporting of the allegations by the press made you an easy target for anyone who wanted to make a claim of sexual misconduct against you? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth. BY MR. PAGLIUCA: Q. And, indeed, there were many people who began falsely claiming that you had engaged in some form of sexual misconduct with them? MR. CASSELL: Form. Foundation. THE WITNESS: Fifth.¶
1 .1. Epstein - Confidential 2 MR. CASSELL: Form. Foundation. Lack 3 of personal knowledge. 4 THE WITNESS: Fifth. 5 BY MR. PAGLIUCA: 6 Q. And you knew rsonally that Mr. Rothstein 7 worked with Mr. because you sued both 8 Mr. Rothstein and Mr. in case captioned 9 Jeffrey Epstein. Plaintiff. versus Scott Rothstein, 10 individually, J. individually, and 11 L.M., individually in 2009, correct? 12 MR. CASSELL: Form. Foundation. Lack 13 of personal knowledge. 14 THE WITNESS: Fifth. 15 BY MR. PAGLIUCA: 16 Q. That would be in 2008. So let me amend 17 that. The question would be in 2008. 18 MR. CASSELL: Form. Foundation. Lack 19 of personal knowledge. 20 BY MR. PAGLIUCA: 21 Q. Your lawyer at the time was somebody named 22 Robert D. Critton, correct? 23 MR. CASSELL: Form, foundation. Lack 24 of proper pronunciation. It's Critton, I 25 think.¶
Page 311 1 J. Epstein - Confidential 2 BY MR. PAGLIUCA: 3 Q. You were also an easy target for 4 unscrupulous lawyers to make those claims and promote 5 those claims against you, correct? 6 MR. CASSELL: Form. Foundation. 7 Vague. 8 THE WITNESS: Fifth. 9 BY MR. PAGLIUCA: 10 Q. For example, there was a lawyer, now 11 disbarred and in prison, named Mr. Rothstein, who was 12 promoting lawsuits against you as part of a Ponzi 13 scheme here, correct? 14 MR. CASSELL: Form. Foundation. 15 THE WITNESS: Fifth. 16 BY MR. PAGLIUCA: 17 Q. And Mr. Rothstein was trying to convince 18 people to buy shares in litigation against you and 19 the outcome of litigation against you, correct? 20 MR. CASSELL: Form. Foundation. 21 THE WITNESS: Fifth. 22 BY MR. PAGLIUCA: 23 Q. Mr. Rothstein worked with an individual 24 named prior to Mr. Rothstein being 25 prosecuted and imprisoned, correct?¶
Page 313 1 J. Epstein - Confidential 2 BY MR. PAGLIUCA: 3 Q. Critton. Okay. C-R-I-T-T-O-N. 4 A. Fifth. 5 Q. You say, Critton. I say, Critton. I don't 6 know how to -- 7 MR. CASSELL: Jack might know. 8 MR. GOLDBERGER: I hate to weigh in on 9 it, but Mr. Cassell's -- Professor Cassell 10 is correct. 11 BY MR. PAGLIUCA: 12 Q. In that lawsuit ou claimed that 13 Mr. Rothstein and Mr. manufactured claims 14 against you, correct? 15 MR. CASSELL: Form. Foundation. 16 THE WITNESS: Fifth. 17 BY MR. PAGLIUCA: 18 Q. In that lawsuit, Sed ot that 19 Mr. Rothstein and Mr. were guilty of criminal 20 conduct, including running a Ponzi scheme, securities 21 fraud, perjury, and other crimes, correct? 22 MR. CASSELL: Form. Foundation. 23 THE WITNESS: Fifth. 24 BY MR. PAGLIUCA: 25 Q. You indicated -- well, isn't it true that¶
1 J. Epstein - Confidential
2 Mr. Rothstein and Mr. [REDACTED] were able to have women
3 change their stories about you and make false
4 allegations against you for money?
5 MR. CASSELL: Form. Foundation.
6 THE WITNESS: Fifth.
7 BY MR. PAGLIUCA:
8 Q. In this case, you are aware that
9 Mr. [REDACTED] ?
10 A. Fifth.
11 Q. And you are aware that Mr. [REDACTED] and a
12 lawyer named Jack Scarola contacted [REDACTED] prior
13 to the filing of any -- of this lawsuit to discuss
14 with her allegations against you and Ms. Maxwell,
15 correct?
16 A. Fifth.
17 Q. Is it -- it is true that Mr. [REDACTED]
18 [REDACTED] with substantial
19 information from both the Palm Beach investigation
20 about you and other information that they had
21 obtained so that they could promote their allegations
22 against you in this litigation, correct?
23 MR. CASSELL: Form. Foundation. Calls
24 for speculation. Lack of personal
25 knowledge.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. PAGLIUCA:
4 Q. It is true, Mr. Epstein, that you did not
5 sexually traffic [REDACTED], correct?
6 MR. CASSELL: Form. Foundation.
7 THE WITNESS: Fifth.
8 BY MR. PAGLIUCA:
9 Q. And it's true, Mr. Epstein, that
10 Ms. Maxwell did nothing to assist you in sexually
11 trafficking [REDACTED], correct?
12 MR. CASSELL: Form. Foundation.
13 THE WITNESS: Fifth.
14 BY MR. PAGLIUCA:
15 Q. The reason you are asserting a Fifth
16 Amendment privilege here today has nothing do with
17 Ghislaine Maxwell, correct?
18 MR. CASSELL: Form. Foundation. Calls
19 for speculation.
20 THE WITNESS: Fifth.
21 MR. GOLDBERGER: And attorney-client
22 privilege.
23 BY MR. PAGLIUCA:
24 Q. The reason you are asserting the Fifth
25 Amendment privilege here today is to protect yourself¶
1 J. Epstein - Confidential
2 from possible prosecution from others, correct?
3 MR. CASSELL: Form. Foundation.
4 THE WITNESS: Fifth.
5 MR. GOLDBERGER: And attorney-client.
6 MR. WEINBERG: Attorney-client
7 privilege.
8 MR. GOLDBERGER: Yeah. We got it.
9 Thanks.
10 MR. WEINBERG: Sorry, Jack.
11 MR. GOLDBERGER: That's all right.
12 BY MR. PAGLIUCA:
13 Q. It is true, Mr. Epstein, you have no
14 loyalty to Ms. Maxwell, as you sit here today,
15 correct?
16 MR. CASSELL: Form. Foundation.
17 THE WITNESS: Fifth.
18 MR. PAGLIUCA: I think I am done. So
19 if you'll give me a minute, I'll go over my
20 notes. We can take a five-minute break.
21 VIDEO TECHNICIAN: Off the record at
22 1:03.
23 (A recess was taken.)
24 VIDEO TECHNICIAN: On the record at
25 1:18.¶
1 J. Epstein - Confidential
2 BY MR. PAGLIUCA:
3 Q. I just have a few more questions,
4 Mr. Epstein.
5 This [REDACTED] person that you've identified
6 as being your girlfriend, this was, roughly, from the
7 end of 1999 that [REDACTED] was your girlfriend, correct?
8 A. Fifth.
9 Q. What's [REDACTED] last name?
10 A. Fifth.
11 Q. And is it true that you had not --
12 MR. CASSELL: I'm sorry. Can we go --
13 the question before the "last name," I
14 should have objected to form and foundation
15 on that one.
16 MR. PAGLIUCA: What was [REDACTED] last
17 name?
18 MR. CASSELL: The one that [REDACTED] was,
19 in fact, your girlfriend. I'm sorry. I
20 apologize. I should have -- form and
21 foundation on that one.
22 MR. PAGLIUCA: I'll give it to you.
23 MR. CASSELL: Thanks.
24 MR. PAGLIUCA: In face, here, I'll ask
25 it again so you can object.¶
1 J. Epstein - Confidential
2 MR. CASSELL: Thank you.
3 BY MR. PAGLIUCA:
4 Q. It is true that [REDACTED] was your girlfriend
5 from approximately the end of 1999, correct?
6 MR. CASSELL: Form and foundation.
7 Thank you.
8 THE WITNESS: Fifth.
9 BY MR. PAGLIUCA:
10 Q. Ms. Maxwell had not been your girlfriend
11 for some time prior to 1999, correct?
12 MR. CASSELL: Form. Foundation.
13 THE WITNESS: Fifth.
14 BY MR. PAGLIUCA:
15 Q. In fact, beginning prior to 1999, you spent
16 less and less time with Ms. Maxwell, correct?
17 MR. CASSELL: Form. Foundation. And
18 -- and chronology.
19 Are you saying -- are you going
20 backwards in time?
21 MR. PAGLIUCA: Yes, I am.
22 MR. CASSELL: Okay. Vague.
23 THE WITNESS: Fifth.
24 BY MR. PAGLIUCA:
25 Q. After 1999, when [REDACTED] was your¶
1 J. Epstein - Confidential
2 girlfriend, Ms. Maxwell spent less and less time in
3 your presence, correct?
4 MR. CASSELL: Form. Foundation.
5 THE WITNESS: Fifth.
6 BY MR. PAGLIUCA:
7 Q. After 1999, when [REDACTED] was your
8 girlfriend, Ms. Maxwell spent less time at any of
9 your residences, correct?
10 MR. CASSELL: Form. Foundation.
11 THE WITNESS: Fifth.
12 BY MR. PAGLIUCA:
13 Q. After 1999, Ms. Maxwell increasingly
14 decreased her visits to the -- your Palm Beach
15 residence, correct?
16 MR. CASSELL: Form. Foundation.
17 THE WITNESS: Fifth.
18 BY MR. PAGLIUCA:
19 Q. After 1999, Ms. Maxwell decreased the
20 frequency of her travels with you, correct?
21 MR. CASSELL: Form. Foundation.
22 THE WITNESS: Fifth.
23 BY MR. PAGLIUCA:
24 Q. And over time, from 1999 moving forward,
25 Miss Maxwell spent less and less time with you,¶
1 J. Epstein - Confidential
2 correct?
3 MR. CASSELL: Form. Foundation.
4 THE WITNESS: Fifth.
5 BY MR. PAGLIUCA:
6 Q. And after 1999, moving forward, Ms. Maxwell
7 spent less and less time, so increasingly less time
8 visiting your house in Palm Beach, correct?
9 MR. CASSELL: Form. Foundation.
10 THE WITNESS: Fifth.
11 BY MR. PAGLIUCA:
12 Q. You were the person responsible for hiring
13 or firing any of your domestic employees from 1998
14 moving forward in time, correct?
15 MR. CASSELL: Form. Foundation.
16 THE WITNESS: Fifth.
17 BY MR. PAGLIUCA:
18 Q. From 1998 moving forward in time, you made
19 all of the decisions with regard to the hiring and
20 firing of any employee, correct?
21 MR. CASSELL: Form. Foundation.
22 THE WITNESS: Fifth.
23 BY MR. PAGLIUCA:
24 Q. From 1998 moving forward, you made all the
25 decisions with regard to the job functions of any of¶
1 J. Epstein - Confidential
2 your domestic employees, correct?
3 MR. CASSELL: Form. Foundation.
4 THE WITNESS: Fifth.
5 BY MR. PAGLIUCA:
6 Q. Is it true that you had a falling out with
7 [REDACTED] because she was increasingly
8 using drugs and abusing drugs from 19 -- 2000 through
9 2002?
10 MR. CASSELL: Form. Foundation.
11 THE WITNESS: Fifth.
12 BY MR. PAGLIUCA:
13 Q. And you had a falling out with [REDACTED]
14 as a result of what you observed to be erratic
15 behavior, including criminal activity?
16 MR. CASSELL: Form. Foundation. Lack
17 of personal knowledge.
18 THE WITNESS: Fifth.
19 BY MR. PAGLIUCA:
20 Q. Do you ever recall meeting anyone named
21 Renaldo Rizzo?
22 MR. CASSELL: Form. Foundation.
23 THE WITNESS: Fifth.
24 BY MR. PAGLIUCA:
25 Q. Ms. Rizzo -- Mr. Rizzo has claimed that he¶
1 J. Epstein - Confidential
2 was at a birthday party at your Palm Beach residence
3 outside by your pool in which the only other
4 attendees were children.¶
5 Is that a true statement or not?
6 MR. CASSELL: Foundation. Misstates
7 the record.¶
8 THE WITNESS: Fifth.
9 BY MR. PAGLIUCA:¶
10 Q. It is, in fact, not true that you had any
11 birthday party with minor children in attendance at
12 your pool in Palm Beach, correct?¶
13 MR. CASSELL: Foundation.
14 THE WITNESS: Fifth.¶
15 BY MR. PAGLIUCA:
16 Q. Mr. Rizzo has also made some claims that
17 you had a number of younger-aged females in a
18 limousine and you went to the [REDACTED] residence in --
19 outside of New York City. Is Mr. Rizzo's statement
20 about that false?¶
21 A. Fifth.¶
22 Q. And it is true that Mr. Rizzo has made up
23 that story about you and the Dubins in an attempt to
24 get money, correct?¶
25 MR. CASSELL: Form. Foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.¶
3 BY MR. PAGLIUCA:¶
4 Q. Mr. Cassell asked you some questions about
5 some -- someone from Sweden who Mr. Rizzo claimed
6 that you somehow lured into the United States for
7 purposes of sexual trafficking.¶
8 That story by Mr. Rizzo is also false,
9 correct?¶
10 MR. CASSELL: Form. Foundation.¶
11 THE WITNESS: Fifth.¶
12 BY MR. PAGLIUCA:¶
13 Q. Do you believe that Eva [REDACTED], a medical
14 doctor, would participate in some scheme to sexually
15 traffic anyone?¶
16 MR. CASSELL: Form. Foundation. Calls
17 for speculation. Lack of personal
18 knowledge.¶
19 THE WITNESS: Fifth.¶
20 MR. PAGLIUCA: That's all the questions
21 I have.¶
22 MR. CASSELL: I may want to consult
23 with Ms. McCawley at some point, but maybe
24 it will make sense for me to try and kind of
25 see --¶
1 J. Epstein - Confidential¶
2 MS. MCCAWLEY: That's fine.¶
3 MR. CASSELL: -- and she'll backstop me
4 in case I miss a trick along the way, so...¶
5 REDIRECT EXAMINATION
6 BY MR. CASSELL:¶
7 Q. We have the advantage by a very skilled
8 court reporter who's given us a -- essentially a
9 real-time transcript here.¶
10 But I noticed that on this real-time
11 transcript, at page 245, line 12, the question was
12 asked to you by Mr. Pagliuca, "Any relationship you
13 had, whether personal or business, ended with
14 Ms. Maxwell more than 15 years ago, correct?"¶
15 Do you recall being asked that question?
16 A. Fifth.¶
17 MR. GOLDBERGER: Well, I think you can
18 answer that -- you recall being asked this
19 question just --¶
20 MR. CASSELL: That's all I'm asking.
21 I'm not trying to trip him up here.¶
22 BY MR. CASSELL:¶
23 Q. Let me just restate that again.¶
24 Do you recall being asked the following
25 question: "Any relationship you had, whether¶
1 J. Epstein - Confidential
2 personal or business, ended with Ms. Maxwell more
3 than 15 years ago, correct?"¶
4 A. What's the question? I'm sorry. Do I
5 remember the question?¶
6 Q. Any relationship you had --¶
7 A. No. Are you asking me do I remember --¶
8 Q. Do you remember being asked that particular
9 question?¶
10 A. Sitting here at the moment, I don't.¶
11 Q. Okay. I want to represent to you that you
12 were asked the question: "Any relationship you had,
13 whether personal or business, ended with Ms. Maxwell
14 more than 15 years ago, correct?"¶
15 A. I took the Fifth to that question, if
16 you're re-asking the question.¶
17 MR. GOLDBERGER: No. I think he's just
18 representing that that question was asked.¶
19 Don't -- and we can establish for purposes
20 of the record that question was asked.¶
21 THE WITNESS: Okay.¶
22 MR. GOLDBERGER: Okay.¶
23 BY MR. CASSELL:¶
24 Q. In fact, you had a number of continuing
25 personal interactions with Ms. Maxwell within the¶
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 J. Epstein - Confidential last 15 years? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. I want to talk to you about some of the personal and other relationships you had with Ms. Maxwell. For example, sir, isn't it true that on December Ilth, 2000, you, Ms. Maxwell, Ms. Taylor, and flew from the West Palm Beach Airport to the Teterboro, New Jersey Airport? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. BY MR. CASSELL: Q. And isn't it true that on December 14th. 2000. you, and Ms. Maxwell and Miss flew from the Teterboro to the U.S. Virgin Islands on your private jet? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth.¶
1 J. Epstein - Confidential 2 I'm sorry, Mr. Pagliuca whether there was any basis 3 in fact for some of the questions I was asking you. 4 Would it be fair to say that one of the 5 bases in fact for asking you questions about 6 Virginia's interactions with Prince Andrew would be a 7 photograph depicting and Prince Andrew? 8 MR. PAGLIUCA: Object to form and 9 foundation. 10 THE WITNESS: Fifth. 11 BY MR. CASSELL: 12 Q. You were asked some about a 13 lawsuit that was styled versus -- I'm sorry, 14 Epstein versus Rothstein, et al. When I ask you a 15 question about the piece of that case, that would be 16 described as your claim against Brad a. 17 Do you understand the setup for the 18 question? 19 A. Yes. 20 Q. You voluntarily dismissed your legal claims 21 against Brad a right? 22 MR. PAGLIUCA: Object to form and 23 foundation. 24 THE WITNESS: Fifth. 25 MR. GOLDBERGER: And attorney-client¶
1 J. Epstein - Confidential 2 BY MR. CASSELL: 3 Q. Isn't it true, sir, that on January 26th, 4 2001. you, Ms. Maxwell, Ms. Taylor. and 5 flew from Teterboro to West Palm Beach? 6 MR. PAGLIUCA: Object to form and 7 foundation. 8 THE WITNESS: Fifth. 9 BY MR. CASSELL: 10 Q. Isn't it true that on March 9th. 2001. you. 11 Ms. Maxwell, Ms. Taylor, and Virginia flew from 12 Tangier, Morocco, to London, England on your private 13 jet? 14 MR. PAGLIUCA: Object to form and 15 foundation. 16 THE WITNESS: Fifth. 17 BY MR. CASSELL: 18 Q. And that was the tri where you, 19 Ms. Maxwell, and met Prince Andrew, the 20 of York. right? 21 MR. PAGLIUCA: Object to form and 22 foundation. 23 THE WITNESS: Fifth. 24 BY MR. CASSELL: 25 Q. Previously you were asked by Ms. Pag-¶
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 J. Epstein - Confidential privilege. BY MR. CASSELL: Q. To your knowledge, there is no lawsuit pending today by you against Mr. right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth. MR. GOLDBERGER: And attorney-client. BY MR. CASSELL: Q. When you traveled to England with Virginia and Ms. Maxwell, Ms. Maxwell held Virginia's passport, right? MR. PAGLIUCA: Object to form and foundation. It has been asked and answered as well. I didn't go into this, and so I'm not sure why we're going over it again. THE WITNESS: Fifth. BY MR. CASSELL: Q. You had a relationship with Ms. Maxwell when you traveled to -- with her to England, right? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Mr. Pagliuca was suggesting there was no
4 basis in fact for some of the questions that I asked.
5 One of the bases in fact would have been
6 Ms. Maxwell's possession of a passport reflecting
7 Virginia's age to be 17 at the time she flew into
8 England with you?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Can you ask the question?
12 BY MR. CASSELL:
13 Q. Isn't that true?
14 MR. PAGLIUCA: Same objection.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. You were asked questions about an e-mail in
18 which you used the phrase "Hold your head high."
19 Do you recall just being asked -- just
20 being asked those questions?
21 A. Yes.
22 Q. I want to talk about the phrase -- now, I
23 want to go into the substantive issues.
24 With regard to the phrase "Hold your head
25 high," the reason you used that phrase is, you didn't¶
1 J. Epstein - Confidential
2 think there was anything wrong with having sex with
3 underage girls, do you?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. In fact, you have used words along the
9 lines of having sex with a minor girl is like
10 stealing a bagel, true?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. And that, in fact, is your view today about
16 the status of having an adult man, decades older than
17 an underage girl, having sex with that underage girl,
18 right?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. What is your view of men who are decades
24 older having sex with 16-year-old girls?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. What is your view of men who are decades
6 older having sex with 17-year-old girls?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. You believe that a man can hold his head
12 high after having sex with a 16-year-old girl even if
13 he's decades older than that girl, true?
14 MR. PAGLIUCA: Object to form and
15 foundation and foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. You were asked various questions by
19 Mr. Pagliuca --
20 MR. CASSELL: Am I pronouncing that --
21 MR. PAGLIUCA: No.
22 MR. CASSELL: I'm sorry.
23 MR. PAGLIUCA: The "G" is silent.
24 Think lasagna.
25 MR. CASSELL: Okay.¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Pal. He's your pal.
3 BY MR. CASSELL:
4 Q. You were asked some questions by
5 Mr. Pagliuca -- got it, okay -- by Mr. Pagliuca about
6 whether this litigation would affect you.
7 You just recall being asked those
8 questions?
9 A. Yes.
10 Q. With regard to those questions, it's true,
11 sir, that this litigation will affect your
12 reputation, right?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. Please describe all the ways in which you
18 foresee this litigation affecting your reputation.
19 MR. PAGLIUCA: Object to the form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. This litigation will affect the reputation
24 of associates of yours, won't it?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. This litigation has the potential to
6 affect the reputation of Bill Clinton, right?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. This litigation has the potential to affect
12 the reputation of Prince Andrew, right?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. This litigation has the potential to affect
18 the reputation of Alan Dershowitz, right?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22
23 BY MR. CASSELL:
24 Q. You could have been a Defendant in this
25 action, right?¶
1 J. Epstein - Confidential
2 [REDACTED] against you, right?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. You understand that if you turned over all
8 the documents that we have requested in this case,
9 that would provide a basis for joining you into this
10 case as a co-Defendant of Ms. Maxwell, right?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. What do all the documents that we have
16 requested of you show with regard to your involvement
17 in Ms. Maxwell's statements against Virginia?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. All the documents that we've requested from
23 you would show that you have coordinated closely with
24 Ms. Maxwell to attack and defame Virginia, right?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. In fact, as a pragmatic matter, you are
7 essentially a Defendant in this action, right?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. You realize that many of the allegations in
13 this litigation involve your interactions with
14 Maxwell, working together against Virginia?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 BY MR. CASSELL:
19 Q. You understand that if you turned over all
20 the e-mails that we requested of you, that would
21 provide a basis for you -- us -- let me rephrase
22 that.
23 You understand that if you turned over all
24 the documents we've requested in the subpoena, that
25 that would provide basis for a defamation action by¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. Ms. Maxwell continues to provide emotional
6 support for you, right?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. Because of the sexual abuse you've
12 committed against girls, you lack very many friends
13 at this point in time, true?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Name anyone who's -- well, strike that.
19 Maxwell has been in a business relationship
20 with you recently, right?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. You and Maxwell need to continue to be in¶
1 J. Epstein - Confidential
2 touch with each other because of interactions that
3 you've had of a business nature, right?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. Please describe the ways in which you and
9 Maxwell's affairs are intertwined currently.
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. Please describe the way yours and Maxwell's
15 business affairs are intertwined currently.
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. You were asked -- and this is kind of a
21 setup question again.
22 You were asked some questions about a
23 lawsuit filed by Jane Doe 1 and Jane Doe 2 against
24 the United States seeking to enforce rights under the
25 Crime Victim Rights Act. Do you recall those general¶
1 J. Epstein - Confidential
2 questions?
3 A. Yes.
4 Q. I want you to assume for a moment that that
5 lawsuit is dismissed tomorrow.
6 If the lawsuit were to be dismissed
7 tomorrow and I were to ask you all of the same
8 questions the day after tomorrow, you would give the
9 same answers, wouldn't you?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 MR. GOLDBERGER: Why don't you do that
13 and we'll find out.
14 THE WITNESS: Fifth.
15 BY MR. CASSELL:
16 Q. That case isn't going to be thrown out,
17 though, because it's meritorious, right?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 MR. GOLDBERGER: And attorney-client
22 privilege.
23 BY MR. CASSELL:
24 Q. In fact, you conspired with the U.S.
25 Attorney's Office to conceal the existence of your¶
1 J. Epstein - Confidential
2 non-prosecution agreement until it was concluded,
3 right?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. The non-prosecution agreement binds the
9 U.S. Attorney's Office for the Southern District of
10 Florida, correct?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 BY MR. CASSELL:
14 Q. I'm sorry. Let me rephrase that.
15 The non-prosecution agreement binds only
16 the U.S. Attorney's Office for the Southern District
17 of Florida, correct?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 MR. GOLDBERGER: And attorney-client
22 privilege.
23 BY MR. CASSELL:
24 Q. Your non-prosecution agreement does not
25 cover sex offenses in -- you have committed in the¶
1 J. Epstein - Confidential
2 State of New York, does it?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 MR. GOLDBERGER: Attorney-client.
7 BY MR. CASSELL:
8 Q. The non-prosecution agreement does not
9 cover sex crimes committed in, for example, the U.S.
10 Virgin Islands or New Mexico, does it?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 MR. GOLDBERGER: Attorney-client.
15 BY MR. CASSELL:
16 Q. You would still be unavailable to testify
17 in the sense that you would have invoked your Fifth
18 Amendment even without that lawsuit, right?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 MR. GOLDBERGER: Attorney-client.
23 BY MR. CASSELL:
24 Q. Which prosecution -- I'm sorry.
25 Which jurisdictions are you fearful might¶
1 J. Epstein - Confidential
2 prosecute you for sex offenses?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 MR. GOLDBERGER: Attorney-client.
7 BY MR. CASSELL:
8 Q. You are fearful of organizations -- I'm
9 sorry.
10 You are fearful of prosecuting entities
11 outside the Southern District of Florida prosecuting
12 you for sex offenses, correct?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 MR. GOLDBERGER: Attorney-client.
17 BY MR. CASSELL:
18 Q. You are fearful of law enforcement
19 organizations outside the United States prosecuting
20 you for foreign sex offenses, correct?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 MR. GOLDBERGER: Attorney-client.
25¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Part of the basis for you asserting your
4 Fifth Amendment privilege today was that you are
5 fearful of incriminating yourself in foreign criminal
6 prosecutions, correct?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 MR. GOLDBERGER: Attorney-client.
11 BY MR. CASSELL:
12 Q. In fact, you lack any basis for asserting
13 the Fifth Amendment privilege with respect to foreign
14 criminal prosecutions, right?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 MR. GOLDBERGER: Attorney-client.
19 BY MR. CASSELL:
20 Q. Please tell me everything you know about
21 your girlfriend [REDACTED].
22 A. Fifth.
23 Q. In fact, during the period 1999 to 2002,
24 Maxwell was your girlfriend, not [REDACTED]?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. Between 1999 and 2002, you had threesomes,
6 right?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. And when you had threesomes, one of the
12 participants in the threesome was your girlfriend,
13 true?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. The threesomes you had almost invariably
19 involved Ghislaine Maxwell, right?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. And when I say they almost invariably
25 involved Ghislaine Maxwell, sometimes you were in¶
1 J. Epstein - Confidential
2 threesomes with other young girls that were not your
3 girlfriend or not --
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. When I look at the flights that
9 [REDACTED] was on between March 8th, 2001, and
10 March -- no, let's see. What do I have? No. I'm
11 sorry. Strike that.
12 If I look at the flights that
13 [REDACTED] is on, according to Dave Roger's
14 flight logs, between December 11th, 2000, and
15 August 21st, 2002, on initial review, I do not see a
16 single entry reflecting a [REDACTED] on those flights.
17 Is that a correct understanding of those --
18 the passengers on those flights?
19 MR. PAGLIUCA: Object to form and
20 foundation. Speculation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Is there some reason [REDACTED] is not found
24 frequently or even at all in the flight logs during
25 this period of time?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form and
3 foundation.
4 THE WITNESS: Fifth.
5 BY MR. CASSELL:
6 Q. Isn't it true that the reason [REDACTED] is not
7 found on these flight logs is, she was not your
8 girlfriend during that period of time?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. And isn't the reason that Ghislaine Maxwell
14 is found, I believe, invariably or certainly almost
15 invariably on these flights -- I guess I should say
16 almost invariably on these flights, is that she was
17 your girlfriend at the time?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. In early 2000, you were having threesomes
23 with Ms. Maxwell, right?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. I believe we already marked as an
5 exhibit --
6 MS. MCCAWLEY: July.
7 MR. CASSELL: [REDACTED], this is the July. Maybe
8 we should mark this as an exhibit. Let me mark
9 this as a new exhibit. I think this is JE14 --
10 MS. MCCAWLEY: I think this is going to
11 be 11.
12 MR. CASSELL: Okay. Strike that. This
13 will become JE11, which I represent is a
14 transcript of Ms. Maxwell taken on
15 July 22nd, 2016. You can take a look. I'm
16 sorry I don't have an extra one.
17 (Plaintiff's Exhibit JE11, Transcript of
18 Ms. Maxwell, taken on July 22, 2016 was marked for
19 identification.)
20 BY MR. CASSELL:
21 Q. I'm looking at page 55. If we look at
22 page 55 -- I'm sorry. If we start at page 54, we
23 see, "Did you engage in sexual activities with anyone
24 other than Mr. Epstein at Mr. Epstein's home in Palm
25 Beach?"¶
1 J. Epstein - Confidential
2 Do you see that question? I'm just asking
3 you whether you see that question.
4 A. Yes, sir.
5 Q. After the inevitable form and foundation
6 question, Mr. Pagliuca, we see an answer, "I did."
7 Do you see that there?
8 A. Yes.
9 Q. And if we continue on down, we see, "Was
10 there more than one person with whom you engaged in
11 sexual activities other than Mr. Epstein at
12 Mr. Epstein's home?" The answer is, "Yes."
13 Do you see that there as well?
14 A. Yes.
15 Q. And you see the questions here: "I don't
16 actually have a name." That's testimony by
17 Ms. Maxwell, right?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Yes.
21 BY MR. CASSELL:
22 Q. This is -- so Ms. Maxwell indicates that
23 she knew the name of the person at that time.
24 You see that on lines 8 and 9 on page 55?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: I'm sorry. Can you
4 repeat the question?
5 BY MR. CASSELL:
6 Q. Yeah. Lines 8 and 9 there's a question:
7 "Did you know the name at that time?" And then line
8 9, "At that time I did."
9 A. I see.
10 Q. Do you see that -- that question there?
11 A. Yes.
12 Q. This is a long way of saying that
13 Ms. Maxwell is indicating that sometime in the late
14 '90s and early 2000s she was having threesomes with
15 you, herself, and another person?
16 A. Is that what it says? I'm sorry.
17 MS. MCCAWLEY: Line 9.
18 BY MR. CASSELL:
19 Q. Line 9 through 10.
20 Maybe I should ask it, if Ms. Maxwell
21 testified that she had threesomes, who would the
22 threesomes have been with?
23 MR. PAGLIUCA: Object to form and
24 foundation.
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. She had threesomes with you and another
4 women, correct?
5 MR. PAGLIUCA: Object to form and
6 foundation.
7 THE WITNESS: Fifth.
8 BY MR. CASSELL:
9 Q. And the other woman was not [REDACTED], was
10 she?
11 MR. PAGLIUCA: Object to form and
12 foundation.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. Who was the other woman in the threesomes
16 that you had in this period of time with Ms. Maxwell?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. The only reason Ms. Maxwell consented to
22 have threesomes with you was that she was your
23 girlfriend at the time, right?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 BY MR. CASSELL:
4 Q. She was, in fact, your girlfriend from the
5 late -- I'm sorry, from around 1996 to around 2005,
6 right?
7 MR. PAGLIUCA: Object to form and
8 foundation.
9 THE WITNESS: Fifth.
10 BY MR. CASSELL:
11 Q. In fact, she actually continued to be your
12 girlfriend into -- into 2006, 2007?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. When did you stop considering Ms. Maxwell
18 to be your girlfriend?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Mr. Pagliuca asked you some questions about
24 [REDACTED]. Do you recall those questions?
25 A. Yes.¶
1 J. Epstein - Confidential
2 Q. [REDACTED] reported to Ghislaine Maxwell,
3 right?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. Ghislaine Maxwell controlled [REDACTED],
9 right?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. Ghislaine Maxwell used [REDACTED] to help
15 bring girls to you for sex, right?
16 MR. PAGLIUCA: Object to form and
17 foundation.
18 THE WITNESS: Fifth.
19 BY MR. CASSELL:
20 Q. What was [REDACTED] role in your
21 household affairs?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Mr. Pagliuca asked you some questions about
4 whether you are an easy target for lawsuits. Do you
5 recall those questions?
6 A. Yes.
7 Q. One of the reasons you were an easy target
8 for lawsuits, sir, was that you sexually abused
9 dozens and dozens of underage girls, right?
10 MR. PAGLIUCA: Object to form and
11 foundation.
12 THE WITNESS: Fifth.
13 BY MR. CASSELL:
14 Q. One of the reasons you were an easy target
15 for [REDACTED] for sexual assault is because
16 you had, in fact, committed sexual assault against
17 [REDACTED]?
18 MR. PAGLIUCA: Object to form and
19 foundation.
20 THE WITNESS: Fifth.
21 BY MR. CASSELL:
22 Q. You settled dozens of lawsuits filed
23 against you by underage girls in 2008 and 2009,
24 didn't you?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. The reason you settled those lawsuits is
6 that you had sexually abused the girls who filed
7 lawsuits you against you, right?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. Every one of the girls who filed a lawsuit
13 against you had been sexually abused by you, right?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. Is there a single girl who has filed a
19 lawsuit against you that lacked merit?
20 MR. PAGLIUCA: Object to form and
21 foundation.
22 THE WITNESS: Fifth.
23 BY MR. CASSELL:
24 Q. When [REDACTED], then known as
25 Jane Doe 102, filed a lawsuit against you, everything¶
1 J. Epstein - Confidential
2 in her lawsuit -- I'm sorry, everything in her
3 complaint against you was true, right?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. If I were to give you an unconditional
9 waiver of the confidentiality form for the lawsuit
10 that Virginia filed against you -- for the settlement
11 that Virginia had of the lawsuit she filed against
12 you, you would refuse to sign that today, right?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 MR. GOLDBERGER: And attorney-client
17 privilege.
18 BY MR. CASSELL:
19 Q. Would you sign an unconditional waiver of
20 confidentiality with regard to the settlement of that
21 lawsuit?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25 MR. GOLDBERGER: Attorney-client¶
1 J. Epstein - Confidential
2 privilege.
3 BY MR. CASSELL:
4 Q. As you sit here today, you continue to
5 maintain loyalty to Ghislaine Maxwell, today, right?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. You were asserting the Fifth Amendment
11 privilege today not only to protect yourself but also
12 to protect Ms. Maxwell, right?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. If you had answered all my questions today,
18 it would have become clear that you were involved
19 with Ms. Maxwell in sex trafficking of underage girls
20 over a multiyear period, right?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. If you had answered all my questions today,¶
1 J. Epstein - Confidential
2 it would have become clear that [REDACTED] has been
3 telling the truth about Ms. Maxwell, right?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. Mr. Pagliuca asked about whether you had
9 terminated relationships with Ms. Maxwell more than
10 15 years ago.
11 You would agree with me, sir, that the time
12 period 2005 -- time period of 2005 would be inside
13 the last 15 years, mathematically?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. You would agree that 2005 is less than
19 15 years ago, as we sit here today, right?
20 A. Yes.
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 BY MR. CASSELL:
24 Q. In 2005, Maxwell had access to certain of
25 your bank accounts, right?¶
1 J. Epstein - Confidential
2 MR. PAGLIUCA: Object to form.
3 Foundation.
4 You already asked these questions, by
5 the way.
6 THE WITNESS: Fifth.
7 BY MR. CASSELL:
8 Q. In 2005, Maxwell had control on certain of
9 your bank accounts, true?
10 MR. PAGLIUCA: Object to form and
11 foundation. Again, you already asked these
12 questions.
13 THE WITNESS: Fifth.
14 BY MR. CASSELL:
15 Q. Previously I never had an opportunity to
16 ask about who was the signatory on your accounts in
17 2005. So I'd like to go over the signatories on your
18 accounts in 2005.
19 Were there any bank accounts in which
20 Maxwell was a signator in 2005, any of your bank
21 accounts?
22 MR. PAGLIUCA: Object to form and
23 foundation.
24 THE WITNESS: Fifth.
25¶
1 J. Epstein - Confidential
2 foundation.
3 I have a question. I've not seen any
4 such bank records. So do you have them and
5 have they been produced?
6 MR. CASSELL: We'll deal with that
7 concern later.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Was Eva [REDACTED] ever your girlfriend?
11 A. Fifth.
12 Q. Please tell me everything you know about
13 Eva [REDACTED].
14 A. Fifth.
15 Q. Have you ever had sex with Eva [REDACTED]?
16 A. Fifth.
17 Q. You, in fact, have had sex with Eva [REDACTED],
18 right?
19 A. Fifth.
20 Q. You paid for Eva [REDACTED] to attend medical
21 school, right?
22 A. Fifth.
23 Q. One of the reasons you paid for Eva [REDACTED]
24 to attend medical school was to keep her quiet about
25 her knowledge of your sexual abuse of minors,¶
Page 359¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. Please describe for me all the signators on
4 your bank accounts in 2005.
5 A. Fifth.
6 Q. I want to talk about the bank accounts that
7 were used to take care of the day-to-day management
8 of your Palm Beach mansion in 2005. Which bank was
9 that account with?
10 A. Fifth.
11 Q. Who was a signatory on that particular
12 account?
13 A. Fifth.
14 Q. If there are bank records that are produced
15 in this case showing Ms. Maxwell as a signator on
16 that account, would those bank records be accurate?
17 MR. PAGLIUCA: Object to form and
18 foundation.
19 THE WITNESS: Fifth.
20 BY MR. CASSELL:
21 Q. It's fair to say that Ms. Maxwell was a
22 signator on the bank account that was involved most
23 heavily in the day-to-day operations of your West
24 Palm Beach mansion, true?
25 MR. PAGLIUCA: Object to form and¶
Page 361¶
1 J. Epstein - Confidential
2 correct?
3 MR. PAGLIUCA: Object to form and
4 foundation.
5 THE WITNESS: Fifth.
6 BY MR. CASSELL:
7 Q. Why did you pay to send Eva [REDACTED] to
8 medical school?
9 MR. PAGLIUCA: Object to form and
10 foundation.
11 THE WITNESS: Fifth.
12 BY MR. CASSELL:
13 Q. Eva [REDACTED] continues to be loyal to you
14 today, true?
15 MR. PAGLIUCA: Object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 MR. CASSELL: I'm getting close to the
19 end. I think this might be a good time for
20 me to confer with counsel for a few minutes.
21 VIDEO TECHNICIAN: Off the record at
22 1:56.
23 (A recess was taken.)
24 VIDEO TECHNICIAN: On the record at
25 2:01.¶
1 J. Epstein - Confidential¶
2 BY MR. CASSELL:¶
3 Q. I want to ask you some questions about a
4 visit to a New York hospital.¶
5 MR. CASSELL: [REDACTED], great. Thank you.¶
6 BY MR. CASSELL:¶
7 Q. You and Ms. Maxwell took Virginia to a
8 New York hospital when she was under the age of 18,
9 correct?¶
10 MR. PAGLIUCA: Object to form and
11 foundation.¶
12 THE WITNESS: Fifth.¶
13 BY MR. CASSELL:¶
14 Q. And at the time, [REDACTED] was in great
15 pain, true?¶
16 MR. PAGLIUCA: Object to form and
17 foundation.¶
18 THE WITNESS: Fifth.¶
19 BY MR. CASSELL:¶
20 Q. Because of the pain [REDACTED] was in, you
21 and Ms. Maxwell handled the admission with the
22 hospital, correct?¶
23 MR. PAGLIUCA: Object to the form and
24 foundation.¶
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential¶
2 BY MR. CASSELL:¶
3 Q. And because you knew it would create
4 complications if Ms. Maxwell was a minor under the
5 age of 18, you and Ms. Maxwell represented that
6 Virginia was 18, true?¶
7 MR. PAGLIUCA: Object to form and
8 foundation.¶
9 THE WITNESS: State your -- you want to
10 repeat your question?¶
11 MR. CASSELL: Sure.¶
12 THE WITNESS: I think you said¶
13 Miss Maxwell was under the age of 18.¶
14 MR. CASSELL: Let me strike the last
15 question and re-ask it. Thank you.¶
16 BY MR. CASSELL:¶
17 Q. Because you knew it would create
18 complications if [REDACTED] was a minor under the
19 age of 18, you and Ms. Maxwell represented that
20 Miss [REDACTED] was 18 years old, true?¶
21 A. Fifth.¶
22 MR. PAGLIUCA: Object to form and
23 foundation.¶
24 BY MR. CASSELL:¶
25 Q. How old did you tell the New York City¶
1 J. Epstein - Confidential¶
2 hospital that [REDACTED] was?¶
3 MR. PAGLIUCA: Object to form and
4 foundation.¶
5 THE WITNESS: Fifth.¶
6 BY MR. CASSELL:¶
7 Q. I'm going to ask you some questions about
8 David Copperfield. You know David Copperfield,
9 right?¶
10 A. Fifth.¶
11 Q. David Copperfield has been in your
12 presence -- has been in your presence -- strike that.¶
13 David Copperfield and you have been
14 together in the presence of minor girls under the age
15 of 18, right?¶
16 MR. PAGLIUCA: Object to form and
17 foundation.¶
18 THE WITNESS: Fifth.¶
19 BY MR. CASSELL:¶
20 Q. Have you ever provided girls under the age
21 of 18 to David Copperfield for sexual purposes?¶
22 MR. PAGLIUCA: Object to form and
23 foundation.¶
24 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential¶
2 BY MR. CASSELL:¶
3 Q. Based on everything I know in this case, it
4 would seem logical that you provided girls under the
5 age of 18 to David Copperfield for sexual purposes.¶
6 Am I missing something if I reach that
7 conclusion?¶
8 MR. PAGLIUCA: Object to form and
9 foundation.¶
10 THE WITNESS: Fifth.¶
11 BY MR. CASSELL:¶
12 Q. With regard to the Palm Beach Police
13 Department investigation, the Palm Beach Police
14 Department identified many persons under the control
15 of Ms. Maxwell, who had paid girls for underage sex?¶
16 MR. PAGLIUCA: Object to form and
17 foundation.¶
18 BY MR. CASSELL:¶
19 Q. True?¶
20 A. There's no question.¶
21 Q. True?¶
22 MR. PAGLIUCA: Same objection.¶
23 THE WITNESS: Fifth.¶
24 BY MR. CASSELL:¶
25 Q. With regard to the girls that the Palm¶
Page 366¶
1 J. Epstein - Confidential¶
2 Beach Police Department investigated, how were the¶
3 payments made to those girls?¶
4 MR. PAGLIUCA: Object to form and¶
5 foundation.¶
6 THE WITNESS: Fifth.¶
7 BY MR. CASSELL:¶
8 Q. Miss Maxwell was aware of all the payments¶
9 that were going to the girls in the Palm Beach Police¶
10 investigation, right?¶
11 MR. PAGLIUCA: Object to form and¶
12 foundation.¶
13 THE WITNESS: Fifth.¶
14 BY MR. CASSELL:¶
15 Q. In fact, Miss Maxwell had control of¶
16 payments that were made to the girls in the Palm¶
17 Beach Police Department investigation?¶
18 MR. PAGLIUCA: Object to form and¶
19 foundation.¶
20 THE WITNESS: Fifth.¶
21 BY MR. CASSELL:¶
22 Q. Ms. Maxwell is one of your closest friends,¶
23 true?¶
24 MR. PAGLIUCA: Object to form and¶
25 foundation.¶
Page 367¶
1 J. Epstein - Confidential¶
2 THE WITNESS: Fifth.¶
3 BY MR. CASSELL:¶
4 Q. How close is your relationship with¶
5 Ms. Maxwell?¶
6 MR. PAGLIUCA: Object to form and¶
7 foundation.¶
8 THE WITNESS: Fifth.¶
9 BY MR. CASSELL:¶
10 Q. Can you name anyone who's a closer friend¶
11 than yours over the last ten years than Miss Maxwell?¶
12 MR. PAGLIUCA: Object to the form and¶
13 foundation.¶
14 THE WITNESS: Fifth.¶
15 BY MR. CASSELL:¶
16 Q. You can't name anyone who's been a closer¶
17 friend of yours over the last ten years than¶
18 Ms. Maxwell, right?¶
19 MR. PAGLIUCA: Object to form and¶
20 foundation.¶
21 THE WITNESS: Fifth.¶
22 BY MR. CASSELL:¶
23 Q. The person that you have had the most¶
24 sexual activity with over the last 20 years is¶
25 Ms. Maxwell, true?¶
Page 368¶
1 J. Epstein - Confidential¶
2 MR. PAGLIUCA: Object to form and¶
3 foundation.¶
4 THE WITNESS: Fifth.¶
5 BY MR. CASSELL:¶
6 Q. Is there anyone over the last 20 years that¶
7 you've had more sexual activity with than¶
8 Ms. Maxwell?¶
9 MR. PAGLIUCA: Object to form and¶
10 foundation.¶
11 THE WITNESS: Fifth.¶
12 BY MR. CASSELL:¶
13 Q. Ms. Maxwell is the longest -- let me see.¶
14 Strike that.¶
15 You haven't had an intimate relationship¶
16 with anyone for a longer period of time than¶
17 Ms. Maxwell over the last two decades, have you?¶
18 MR. PAGLIUCA: Object to form and¶
19 foundation.¶
20 THE WITNESS: Fifth.¶
21 BY MR. CASSELL:¶
22 Q. Through legal counsel and other means, you¶
23 have been coordinating with Ms. Maxwell with regard¶
24 to this litigation, right?¶
25 MR. PAGLIUCA: Object to form and¶
Page 369¶
1 J. Epstein - Confidential¶
2 foundation.¶
3 THE WITNESS: Fifth.¶
4 MR. GOLDBERGER: Attorney-client¶
5 privilege.¶
6 BY MR. CASSELL:¶
7 Q. You purchased a town home in New York for¶
8 Miss Maxwell for millions of dollars, true?¶
9 MR. PAGLIUCA: Object to form and¶
10 foundation.¶
11 You've already asked this question.¶
12 It's already been answered.¶
13 THE WITNESS: Fifth.¶
14 BY MR. CASSELL:¶
15 Q. How are you coordinating with Ms. Maxwell¶
16 on this litigation?¶
17 MR. PAGLIUCA: Object to form and¶
18 foundation.¶
19 THE WITNESS: Fifth.¶
20 BY MR. CASSELL:¶
21 Q. You're hoping Ms. Maxwell prevails in this¶
22 litigation, true?¶
23 MR. PAGLIUCA: Object to form and¶
24 foundation.¶
25 THE WITNESS: Fifth.¶
1 J. Epstein - Confidential
2 BY MR. CASSELL:
3 Q. What is your arrangement with Ms. Maxwell
4 with regard to paying any settle -- any judgment that
5 might be reached against her in this case?
6 MR. PAGLIUCA: Object to form and
7 foundation.
8 THE WITNESS: Fifth.
9 BY MR. CASSELL:
10 Q. Ms. Maxwell has had discussions with the you
11 about whether you would pay a judgment in this action
12 against her, right?
13 MR. PAGLIUCA: Object to form and
14 foundation.
15 THE WITNESS: Fifth.
16 BY MR. CASSELL:
17 Q. Your interests in Ms. Maxwell are
18 compatible in this case, true?
19 MR. PAGLIUCA: Object to form and
20 foundation.
21 THE WITNESS: Fifth.
22 BY MR. CASSELL:
23 Q. Both you and Ms. Maxwell are hoping that
24 the case would be dismissed, true?
25 MR. PAGLIUCA: Object to form and¶
1 J. Epstein - Confidential
2 foundation.
3 THE WITNESS: Fifth.
4 BY MR. CASSELL:
5 Q. Previously you sent e-mails to Ms. Maxwell
6 indicating your desire to have the publicity in this
7 case die down, right?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. If the case were to settle, that would help
13 the publicity in this case die down, right?
14 MR. PAGLIUCA: Object to form and
15 foundation.
16 THE WITNESS: Fifth.
17 BY MR. CASSELL:
18 Q. If this case were to resolve, that would be
19 useful for your purposes and Maxwell's purposes,
20 right?
21 MR. PAGLIUCA: Object to form and
22 foundation.
23 THE WITNESS: Fifth.
24 BY MR. CASSELL:
25 Q. You have also been coordinating with¶
1 J. Epstein - Confidential
2 Alan Dershowitz with regard to this litigation,
3 right?
4 MR. PAGLIUCA: Object to form and
5 foundation.
6 THE WITNESS: Fifth.
7 MR. GOLDBERGER: And attorney-client
8 privilege.
9 BY MR. CASSELL:
10 Q. You are in a joint defense arrangement with
11 Alan Dershowitz at this time?
12 MR. PAGLIUCA: Object to form and
13 foundation.
14 THE WITNESS: Fifth.
15 MR. GOLDBERGER: Attorney-client
16 privilege -- I'm sorry. Attorney-client
17 privilege, and to the extent there is a
18 confidentiality agreement in place or -- or
19 a joint defense agreement, I would object on
20 that basis.
21 BY MR. CASSELL:
22 Q. You have a common interest agreement with
23 Alan Dershowitz, right?
24 MR. PAGLIUCA: Object to form and
25 foundation.¶
1 J. Epstein - Confidential
2 THE WITNESS: Fifth.
3 MR. GOLDBERGER: Attorney-client
4 privilege.
5 BY MR. CASSELL:
6 Q. You have a common interest with
7 Alan Dershowitz in this litigation, right?
8 MR. PAGLIUCA: Object to form and
9 foundation.
10 THE WITNESS: Fifth.
11 BY MR. CASSELL:
12 Q. You have a common interest with
13 Ghislaine Maxwell in this litigation, right?
14 MR. PAGLIUCA: Asked and answered, this
15 question. I'm going to object to form and
16 foundation.
17 THE WITNESS: Fifth.
18 MR. CASSELL: I have no further
19 questions.
20 MR. PAGLIUCA: I have no additional
21 questions.
22 MR. GOLDBERGER: Excellent.
23 MR. CASSELL: Thank you.
24 VIDEO TECHNICIAN: The time is 2:08.
25 This concludes the deposition.¶
7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 J. Epstein - Confidential 2 MR. PAGLIUCA: I do want a transcript. 3 THE COURT REPORTER: Do you have a 4 standing order? 5 MR. PAGLIUCA: Yeah. They should have 6 whatever we want. I think it's E-Tran. THE COURT REPORTER: A rough transcript? MR. PAGLIUCA: I don't need a rough, I don't think. (Signature was not waived. The deposition concluded at 2:08 p.m.)¶
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 REPORTER'S CERTIFICATE STATE OF FLORIDA COUNTY OF PALM BEACH I, DARLINE WEST, RPR, certify that I was authorized to and did stenographically report the foregoing deposition; and that the transcript is a true record thereof. I further certify that I am not a relative, employee, attorney, or counsel of any of the parties. nor am I a relative or employee of any of the parties' attorney or counsel connected with the action, nor am I financially interested in the action. Dated this 13th day of September 2016. DARLINE WEST. RPR¶
1 CERTIFICATE OF OATH 2 3 STATE OF FLORIDA 4 COUNTY OF PALM BEACH 5 6 7 I, the undersigned authority, certify that 8 JEFFREY EPSTEIN personally appeared before me and was 9 duly sworn on September 9.2016. 10 11 WITNESS my hand and official seal this 13th day 12 of September 2016. 13 14 15 16 DARLINE WEST Notary Public 17 18 19 20 21 22 23 24 25 My Commission Expires: October 26, 2017 #FF 060662¶
1 2 CERTIFICATE STATE OF FLORIDA 3 COUNTY OF PALM BEACH 4 5 I, JEFFREY EPSTEIN, hereby certify that I 6 have read the foregoing transcript of my deposition 7 and that the statements contained therein, together 8 with any additions or corrections made on the 9 attached Errata Sheet, are true and correct. 10 11 12 Dated this day of 2016. 13 14 15 16 17 18 19 JEFFREY EPSTEIN The foregoing certificate was subscribed to before me this day of 2016. 20 by the witness who has produced a as identification and who did 21 not take an additional oath. 22 23 24 Notary Public 25 my commission expires:¶
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